Employer Verification of Behaviours in Apprenticeships: What Employers and Providers Need to Know

New guidance on employer verification of behaviours has been published as part of wider apprenticeship assessment reforms.

For many employers, the practical impact should be limited: behaviour monitoring is already part of routine workplace management, supervision and staff development. However, the guidance is important because it clarifies who is responsible for confirming that apprentices have demonstrated the required behaviours before completion.

In simple terms, behaviours remain mandatory, but they are verified by the employer rather than separately assessed by the Awarding Organisation.

The guidance sits within the wider apprenticeship assessment reforms introduced through the Apprenticeship Assessment Principles and the move towards a more proportionate assessment system.

The reforms follow a Department for Education review which identified that apprenticeship assessment could be overly complex, burdensome and time consuming. The new approach is intended to simplify assessment arrangements, reduce duplication and maintain confidence in apprentice competence.

This article summarises the key points from the published guidance and considers what they mean in practice for employers, training providers and Awarding Organisations.

What has changed

Under the revised arrangements, employers are responsible for verifying that apprentices have demonstrated the behaviours set out in the relevant occupational standard.

This reflects the position that employers are well placed to observe behaviours over time in the workplace and to confirm whether they have been demonstrated consistently in practice.

The guidance doesn’t introduce a separate assessment of behaviours by Awarding Organisations. Instead, employers are expected to use evidence arising naturally through normal workplace activity, where appropriate. This may include:

• Line management and supervision discussions

• Performance reviews

• Workplace observations

• Mentoring and coaching conversations

• Regular feedback and development discussions

Behaviours remain a mandatory requirement

The change relates to how behaviours are verified, not whether they are required.

Behaviours remain part of every occupational standard and must be met before apprenticeship completion can be confirmed.

The guidance confirms that behaviours are required for certification but do not contribute to grading decisions. Apprentices must also meet all other relevant completion requirements, including gateway requirements, mandated qualifications and English and math requirements where these apply.

A proportionate approach to evidence

A central feature of the guidance is proportionality.

Employers are not expected to create extensive portfolios or duplicate existing evidence systems where workplace processes already provide a clear basis for confirming behavioural competence.

An optional behaviour checklist is also available for employers who may find it useful. Where employers already have established performance, development or supervision processes, those arrangements may provide the appropriate basis for verification, provided the required behaviours are covered and confirmation is clear.

Roles and responsibilities

The guidance clarifies the respective roles of employers, apprentices, training providers and Awarding Organisations.

• Apprentices are expected to demonstrate the behaviours in their occupational standard and engage with feedback during their programme.

• Employers are responsible for observing and confirming that the required behaviours have been demonstrated consistently in the workplace.

• Training providers continue to support progress, prepare apprentices and maintain engagement with employers, but they are not responsible for assessing or quality assuring the employer’s verification decision.

• Awarding Organisations continue to design and deliver assessment in line with the relevant assessment plan and regulatory requirements, with behaviours verified by the employer rather than assessed separately by the Awarding Organisation.

What this means for employers

For many employers, this should not require a significant change in day-to-day practice. Behaviour monitoring is often already embedded within routine workplace management, supervision, mentoring and staff development.

However, employers should review their apprenticeship processes to ensure that behavioural expectations are understood, monitored and confirmed before completion.

• Discuss behaviour expectations early in the apprenticeship.

• Ensure managers and mentors understand the occupational standard requirements.

• Review behavioural development regularly as part of normal workplace activity.

• Keep a clear record of employer confirmation before apprenticeship completion.

What this means for Training Providers and Awarding Organisations

For training providers, the key point is that they are not being asked to assess or quality assure employer behaviour verification decisions. Their role is to support apprentices and employers by helping to ensure that behaviour expectations are understood, discussed and monitored throughout the programme.

For Awarding Organisations, the guidance provides helpful clarity on the boundary between employer verification of behaviours and formal assessment activity.

It supports a model in which behaviours remain mandatory, workplace-based and linked to occupational competence, while avoiding unnecessary duplication within assessment design and delivery.

The overall direction is clear: apprenticeship assessment should remain rigorous and credible while becoming more proportionate, streamlined and aligned to how competence is demonstrated in real workplace settings.

The original GOV.UK guidance can be accessed here: Employer verification of behaviours.

Need support with apprenticeship assessment?

If you have questions about what the new Employer Verification of Behaviours Guidance means for your organisation, we can help.

Get in touch with us to discuss how the guidance may apply to your programmes, melanie.feek@elevateawarding.co.uk