Published: 4 August 2026
Skills England updated its employer guidance on apprenticeship behaviour verification on 21 July 2026. The direction is deliberately practical: employers hold primary responsibility for confirming that an apprentice has demonstrated the behaviours in the occupational standard because they observe the apprentice over time in real work.
The guidance also says the process should be proportionate. Employers should record or log naturally occurring examples through established supervision, feedback and development processes. It is not an invitation to build a second assessment portfolio.
Revised apprenticeship assessment plans are being introduced standard by standard. Providers must identify the occupational standard version, assessment plan and requirements that apply to each apprentice rather than treating reform as a single universal switch-over.
What the guidance changes operationally
Behaviour verification is a completion control, not a tutor's impression and not an assessment-organisation grading exercise. The employer needs enough understanding of the listed behaviours to make a genuine judgement. The provider needs a reliable process for explaining what is required, prompting review at the right time and retaining the confirmation.
The most useful provider role is therefore orchestration:
- map the behaviours from the correct standard version;
- identify an authorised workplace verifier;
- help the apprentice notice suitable examples in normal work;
- make manager review short and specific;
- record clarification, changes and final confirmation;
- surface missing verification before gateway to completion.
A six-stage manager verification workflow
1. Configure the correct behaviours
Start with the published occupational standard and applicable assessment plan. Store the standard code and version with the learner record. Translate each behaviour into plain-language review prompts without changing its meaning.
For example, a behaviour about taking responsibility might prompt: “Describe one routine or difficult situation in which the apprentice took ownership. What did you observe, and what was the result?” The prompt directs attention without inventing a new assessment criterion.
2. Name the authorised verifier
Agree who will make the employer judgement during onboarding. This is usually the line manager or another person who regularly observes the apprentice's work and has authority to confirm the employer's position.
Record a deputy as well. Manager changes, long-term absence and organisational restructures should not leave verification ownerless at the end of the programme.
3. Capture naturally occurring examples
Use routine work: feedback from a client interaction, ownership of a task, contribution to a team decision, response to a safety concern or reflection after an error. The objective is not to produce a large volume of attachments. It is to make a small number of credible examples easy for the manager to recall and confirm.
An example record can be concise: date or period, situation, behaviour demonstrated, manager observation and any development action. Link to an existing review note or work record only where useful and appropriate.
4. Review before the final checkpoint
Do not send every behaviour to the manager for the first time at gateway. Include a light-touch readiness check in normal progress reviews. This lets the employer identify behaviours that have not yet been seen consistently and gives the apprentice time to develop.
The progress review remains distinct from final employer confirmation. It is the place to surface gaps and agree opportunities for observation.
5. Ask for a clear decision
At the appropriate point, present the applicable behaviours, the supporting examples and three clear states:
- Verified: the employer confirms the behaviours have been demonstrated.
- Changes or clarification required: the manager needs a correction or additional information before deciding.
- Not yet verified: the behaviour has not been demonstrated consistently enough.
A digital tick without context may be fast but weak. A short confirmation tied to the correct standard version, verifier and date is both efficient and auditable.
6. Lock the confirmation and retain the history
Once verified, retain the employer's name, role, organisation, decision date, standard version and confirmation. Keep prior requests for clarification in the audit history. If a material correction is made later, create a new version rather than silently overwriting the original record.
The minimum useful verification record
| Field | Why it matters |
|---|---|
| Apprentice and employer | Identifies whose workplace performance is being confirmed. |
| Standard code and version | Prevents confirmation against the wrong set of behaviours. |
| Behaviour statement | Makes the scope of the judgement explicit. |
| Naturally occurring example | Gives the verifier a concrete basis for reflection. |
| Verifier name, role and relationship | Shows why the person is positioned to make the judgement. |
| Decision and date | Records the employer's formal confirmation. |
| Comments or changes requested | Preserves development feedback and decision history. |
Providers should align the final record with current Skills England guidance, their assessment organisation's arrangements and their own data-protection controls.
Flexi-job and multiple-host settings
Where an apprentice works with more than one host employer, the lead employer or flexi-job apprenticeship agency may not observe every behaviour directly. The guidance recognises that host employers can provide feedback from routine work, while the lead employer brings that information together and makes the verification decision.
The workflow therefore needs to distinguish feedback contributor from authorised verifier. Host feedback should show the setting and period of observation. The final record should make clear who aggregated that feedback and confirmed the employer's decision.
What to avoid
- Creating simulated tasks solely to manufacture behaviour evidence
- Asking an employer contact who rarely sees the apprentice to confirm every behaviour
- Collecting dozens of screenshots where a short workplace observation would be clearer
- Using the behaviours from the latest standard version for apprentices on an earlier version
- Conflating a progress-review comment with final employer verification
- Letting a training provider employee approve on behalf of the employer
- Waiting until gateway to discover that the named manager has left
A 30-day provider implementation plan
- Week one: identify revised plans in active delivery and map their behaviours.
- Week two: define verifier roles, plain-language prompts and the minimum record.
- Week three: test the workflow with a small group of managers and measure completion time.
- Week four: add reminders, exception reporting and a gateway-readiness view.
The test is simple: can an authorised manager understand what they are confirming, review credible examples from normal work and make a recorded decision without navigating an assessment system built for specialists? If the answer is yes, the workflow is likely close to the proportionate model the guidance intends.
Frequently asked questions
Does an employer need to create a new behaviour assessment system?
No. Skills England says verification should be proportionate and integrated with normal supervision, feedback, check-ins and performance development rather than creating extensive new evidence or paperwork.
Do behaviours contribute to the apprenticeship grade?
Under the revised assessment model, behaviours must be developed and verified but do not contribute to the apprenticeship grade. Providers must still follow the plan and requirements that apply to the individual apprentice.
Can the training provider sign off behaviours for the employer?
The updated model gives the employer primary responsibility for verification. A provider can structure the process, explain the occupational behaviours and retain the record, but should not substitute its judgement for the authorised employer's confirmation.
Sources & further reading
- Skills England — Apprenticeship behaviour verification guidance for employers
- Skills England — Requirements and guidance for apprenticeship assessment
- DWP — Changes to apprenticeship assessment