Functional skills requirements for apprenticeships: a compliance guide

What the requirement is

Before an apprentice can be recommended for gateway, they must hold — or have achieved during their programme — a Level 2 qualification in both English and maths. The standard qualification pathway is Functional Skills Level 2, delivered by an approved awarding organisation.

This requirement exists for all apprenticeship standards in England unless the standard explicitly states a different requirement (rare, and typically for higher-level standards where a degree or equivalent already covers literacy and numeracy demands).

The requirement applies regardless of:

• The learner's age
• How long they have been in employment
• The level of the apprenticeship standard
• Whether the employer considers it relevant to the job role

Exemptions: what qualifies

A learner is exempt from working towards functional skills if they already hold a qualifying prior qualification. The following are accepted as exemptions:

• GCSE English Language — grade 4 (or grade C in legacy grading) or above
• GCSE Mathematics — grade 4 (or grade C) or above
• A-level English or Mathematics — any pass grade
• Functional Skills Level 2 — achieved previously (certificate required)
• Key Skills Level 2 — in the relevant subject (legacy; still accepted)

The following do not qualify as exemptions, regardless of grade or subject content:

• BTEC Nationals or Firsts with English or maths units
• Level 3 or above vocational qualifications
• International qualifications — these must be formally verified against ESFA guidance and may require an equivalency check through a recognised awarding organisation
• Internal provider assessments

You must retain a copy of the exempting certificate in the learner's record. A self-declaration by the learner is not sufficient.

Functional skills Level 1 — what it means

Some learners will begin their programme with no qualifications in maths or English, or with evidence of difficulty that makes Level 2 achievement within the programme timeline a risk. In these cases, providers have a duty to:

• Identify the starting point through initial assessment at sign-up
• Enrol the learner on an appropriate pathway — which may start at Entry Level or Level 1 before progression to Level 2
• Set realistic timescales and monitor progress at every review
• Flag risk early if the learner is unlikely to achieve Level 2 before gateway

A learner who achieves only Level 1 during their programme cannot proceed to gateway for their apprenticeship standard. This is a hard gate. Providers need to plan for this scenario — not encounter it six weeks before the planned gateway date.

Common delivery models

Training providers typically deliver functional skills through one of three models:

In-house delivery

The provider employs or contracts functional skills tutors and delivers maths and English directly to learners. This gives control over scheduling and integration with the main programme but requires awarding organisation centre approval and quality assurance processes.

Sub-contracted delivery

The provider sub-contracts functional skills delivery to a specialist provider. This is common among employers-led providers and those without scale to justify in-house delivery. Due diligence on the sub-contractor — including their achievement rates and Ofsted judgement — is the main provider's responsibility.

Employer-arranged delivery

Some employers arrange functional skills delivery through their own training teams or a separate provider. This requires careful coordination to ensure the provider has sight of achievement, the learner record is updated, and certificates are collected before gateway.

Regardless of delivery model, the main provider is responsible for tracking completion and retaining evidence of achievement.

Tracking compliance across a cohort

Functional skills tracking is a significant operational overhead if managed manually. The recommended approach is to track status as a field on every learner record, updated after every review:

• Exempt — prior qualification confirmed and certificate retained
• Enrolled — learner is on a functional skills programme; Level and target date recorded
• In progress — learner has sat at least one component; partial achievement recorded
• Achieved — Level 2 certificate retained in learner record
• At risk — learner is behind expected progress or has failed an attempt

Any learner with status "at risk" should be discussed at the next progress review, with a specific SMART target and a revised timeline for achievement.

Gateway implications

Functional skills is one of the mandatory gateway requirements. A learner cannot be recommended for EPA by the provider, and cannot be signed off by the employer, until the maths and English requirement is confirmed as met.

In practice this means:

• The gateway declaration should include a specific field confirming functional skills status
• The EPAO may request evidence of achievement before confirming EPA booking
• If a learner passes all other gateway requirements but has not completed functional skills, the programme must be extended until they do — or until the provider formally records a planned end date extension with the rationale

Use the EPA gateway readiness checker to validate functional skills status alongside other gateway requirements before recommending any learner.

What Ofsted looks for

Ofsted inspectors assess English and maths delivery as a distinct strand of the inspection — not just as a compliance checkbox. They will look for:

• Evidence that initial assessment identified the learner's starting point accurately
• A clear, individualised progression route from starting point to Level 2
• Integration of English and maths into the main programme — not delivered as an isolated add-on
• Achievement rates in functional skills that are at least in line with national benchmarks
• Evidence that learners who are struggling are identified early and supported

Low functional skills achievement rates, or high rates of learners reaching gateway without having completed maths and English, are likely to result in a concern or a recommendation in the inspection report.

Frequently asked questions

Do all apprentices need Level 2 English and maths?

Yes, unless they already hold an exempting qualification. Apprentices who do not hold a GCSE grade 4 or above (or equivalent) in English and maths must work towards Level 2 Functional Skills as part of their programme. This is a gateway requirement — they cannot proceed to EPA until it is met.

What qualifications exempt an apprentice from functional skills?

A GCSE grade 4 (previously grade C) or above in English Language and Mathematics exempts an apprentice from the functional skills requirement. A-level grades in these subjects also qualify. International equivalents may be accepted but must be verified against ESFA guidance. BTECs and other vocational qualifications do not exempt.

Can an apprentice go to EPA gateway without passing functional skills?

No. Functional skills at the appropriate level is a mandatory gateway requirement. An apprentice who has not met the maths and English requirement cannot be signed off for gateway, even if all other KSBs are evidenced and OTJ hours are complete.

Does functional skills count as OTJ hours?

Yes. Time spent on functional skills training counts as off-the-job training, provided it takes place during the apprentice's normal working hours and is directly relevant to the apprenticeship standard. It must be recorded and approved in the same way as all other OTJ activity.