Maths and English Requirements in Apprenticeships: 2025/26 Policy Changes Explained

Last updated: 19 March 2026

The Maths and English Requirement in Apprenticeships

The maths and English requirement in English apprenticeships is longstanding. Before an apprentice can be signed off for gateway and proceed to End-Point Assessment (EPA), they must demonstrate an appropriate level of competence in both literacy and numeracy. The rationale is straightforward: occupational competence cannot be assessed in isolation from the underpinning communication and numeracy skills that every job role requires.

The requirement operates on a two-tier structure. All apprentices who do not already hold a prior Level 2 qualification in maths and English must, as a minimum, be working towards those qualifications during their programme. For most apprenticeship standards at Level 3 and above, the requirement goes further: the apprentice must achieve Level 2 Functional Skills (or equivalent) as a gateway condition before EPA can take place.

The qualification pathways are:

• Functional Skills Level 2 — the primary route for learners without prior qualifications. Assessed by an approved Awarding Organisation (City & Guilds, Pearson, AQA, NCFE, and others). Covers reading, writing, and speaking, listening and communicating for English; and a range of applied numeracy skills for maths.
• Functional Skills Level 1 — a stepping stone, not a gateway qualification for most Level 3+ standards. Learners who begin at Entry Level or Level 1 must progress to Level 2 before gateway, unless the standard specifies otherwise or an exemption applies.
• GCSE equivalence — GCSE English Language at grade 4 (previously grade C) or above, and GCSE Mathematics at grade 4 or above, are the most common prior qualifications that satisfy the Level 2 requirement. A-levels in English or Mathematics (any pass grade) also qualify.

The requirement applies separately for maths and for English. A learner who holds a GCSE in Mathematics at grade 5 but has no English qualification must still achieve Functional Skills Level 2 in English before gateway, and vice versa.

What Changed for 2025/26

The 2025/26 ESFA apprenticeship funding rules introduced a more explicit framework around who must achieve functional skills versus who must only work towards them. Providers should read the current year’s funding rules document in full for their specific standards, but the key policy directions are as follows.

Clearer distinction between ‘achieve’ and ‘work towards’. For Level 3 and above apprenticeship standards, the default position remains that achievement of Level 2 in maths and English is a gateway condition. However, the 2025/26 rules formalised the circumstances in which a learner may proceed to gateway having only worked towards (rather than achieved) Level 2, particularly for learners with specific learning difficulties or disabilities (SpLD) where achievement is not a reasonable expectation within the programme timeline.

Level 2 standard exceptions. For apprenticeship standards at Level 2, the requirement has always been to work towards English and maths at Level 1, not Level 2. This remains unchanged. However, the 2025/26 rules clarified the evidencing requirements around what ‘working towards’ must demonstrate — enrolment alone is insufficient; providers must show active engagement and progress.

Changes to the exceptions policy. The updated rules tightened the evidence threshold for applying exceptions. Where a provider previously might have applied a broad learning difficulty exception with limited supporting documentation, the 2025/26 rules require more specific, contemporaneous evidence of the learning difficulty, its impact on maths and English achievement, and what alternative support or adjustments were provided.

Note on evolving policy. Maths and English policy in apprenticeships is subject to ongoing reform, particularly as Skills England develops its recommendations and the Growth and Skills Levy takes shape. Providers should check the current ESFA funding rules and any associated guidance updates for their specific standards — do not rely solely on this article for compliance purposes.

Who Is Exempt and Who Is Not

The exemption landscape is frequently misunderstood. The following categories apply:

Learners with prior Level 2 attainment

Any learner who holds an accepted prior qualification at Level 2 or above in English and/or maths is fully exempt from the functional skills requirement for that subject. Accepted qualifications include:

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

The exemption requires a certificate or verified copy. A learner who cannot produce a certificate must be treated as non-exempt and enrolled on functional skills provision. Providers should collect and store certificates at programme start, not at gateway.

Learners who have attempted and failed

A learner who has attempted functional skills qualifications and not yet achieved them is not exempt. Their status should be recorded as ‘at risk’ or ‘in progress’, and the provider must work with them on a revised plan for achievement. Repeated failures do not create an automatic exemption — they require a review of delivery, additional support, and (if appropriate) a formal learning difficulty assessment to determine whether an exception process should be initiated.

Learners with disabilities or learning difficulties

Learners with a diagnosed specific learning difficulty (such as dyslexia), a physical disability affecting literacy or numeracy, or an Education, Health and Care Plan (EHCP) may be eligible for the exception process. This is not an automatic exemption. The provider must:

• Obtain and retain evidence of the learning difficulty or disability (assessment report, EHCP, or equivalent)
• Document why achievement of Level 2 is not a reasonable expectation within the programme
• Show what alternative support and reasonable adjustments were provided
• Confirm the learner is still working towards the qualification to the extent they are able

Applying the exception process without adequate evidence is one of the most common audit findings ESFA makes in relation to maths and English compliance.

Employer-provider cases

Employer-providers (employers who are themselves on the register of apprenticeship training providers) are subject to the same maths and English requirements as external training providers. There is no different rule for in-house delivery. The employer-provider must still enrol learners, track achievement, and hold certificates.

What Providers Must Evidence

The ILR (Individualised Learner Record) is the primary mechanism through which ESFA monitors maths and English compliance. Providers must record the correct data fields, at the right time, to avoid audit findings.

ILR recording requirements

The key ILR fields for maths and English are:

• Prior attainment — if the learner holds an exempting qualification, record the prior attainment level in the relevant ILR field at the point of programme start. This signals that no functional skills enrolment is required.
• Functional skills aim — where the learner requires functional skills, record a separate learning aim for English and maths at the appropriate level, with the correct Learning Aim Reference from the ESFA’s Learning Aim Reference Service (LARS).
• Enrolment date — functional skills aims should be recorded from the point of enrolment, not from first attendance or from the point the learner passes. Late ILR recording is a common audit trigger.
• Achievement date and outcome — when a learner achieves, record the achievement date and the pass outcome against the relevant learning aim. Where a learner does not achieve, record the appropriate withdrawal or completion code.

Common ILR errors around maths and English

The most frequent errors found in ESFA data audits are:

• Functional skills aims not recorded in the ILR at all (learner treated as exempt without adequate evidence)
• Aims recorded with incorrect Learning Aim References (causing data validation failures)
• Achievement dates recorded after the gateway date, suggesting the learner was signed off before maths and English were confirmed
• Prior attainment fields left blank for learners who do hold exempting qualifications (triggering unnecessary compliance queries)
• Incorrect completion codes for learners who withdrew from functional skills but continued on the main programme

Choosing a Functional Skills Provider

Many apprenticeship providers sub-contract functional skills delivery to a specialist Functional Skills centre rather than delivering in-house. This is a legitimate and common model, but it creates specific governance obligations for the main provider.

Awarding Organisation requirements

Functional skills qualifications can only be delivered and assessed by centres approved by an Ofqual-regulated Awarding Organisation. The main AOs active in this space are City & Guilds, Pearson, AQA, NCFE, and Open Awards. Each has its own centre approval process, quality assurance requirements, and assessment scheduling protocols.

If your organisation is sub-contracting to an FS centre, check that:

• The centre is currently approved by their AO (approval can lapse)
• The centre’s Ofsted grade (if they have one) is acceptable — ESFA expects sub-contractor due diligence
• There is a signed sub-contracting agreement in place covering data sharing, achievement reporting, and quality oversight
• The centre can accommodate your learners’ scheduling needs and geographic spread

Tracking achievement alongside the apprenticeship programme

The main provider remains responsible for tracking functional skills achievement even when delivery is sub-contracted. This requires a structured data-sharing process: the FS centre must report achievement back to the provider promptly enough for the provider to update the ILR and learner record before gateway. A process that relies on manual emails close to gateway is not sufficient — build a systematic reporting cadence into the sub-contracting agreement.

What Happens if Learners Don’t Achieve Functional Skills

This is one of the most operationally consequential areas of maths and English policy, and one of the most poorly planned for by providers.

Impact on gateway

A learner who has not met the maths and English requirement cannot be recommended for gateway. Full stop. Even if all KSBs are evidenced, OTJ hours are complete, the employer is ready to sign off, and the EPAO has a slot available — the learner cannot proceed. The programme must be extended until the requirement is met, or (in genuine exception cases) until the exception process has been correctly completed and documented.

Ofsted scrutiny on functional skills delivery quality

Ofsted inspectors assess English and maths not merely as a compliance data point but as a quality indicator. Inspectors want to see:

• Initial assessment at programme start that genuinely identifies the learner’s starting point
• An individualised plan from starting point to Level 2, with realistic milestones
• English and maths embedded in main programme delivery — not treated as an entirely separate bolt-on
• Tutors who can speak to how they develop learners’ maths and English skills within the vocational context
• Achievement rates in functional skills that are in line with or above national benchmarks

Low achievement rates are a significant Ofsted concern. If a provider has a high proportion of learners who reach gateway but have not completed functional skills, or who withdraw from the programme with functional skills unachieved, this will feature in inspection findings.

Implications for achievement rate data

Functional skills achievement (or non-achievement) feeds into the national achievement rate tables. For providers funded through ESFA, poor functional skills achievement rates can affect quality performance assessments and, over time, future funding decisions. Functional skills is not a separate programme for achievement rate purposes — it is recorded as part of the apprenticeship aim — but ESFA and Ofsted both look at the data as part of provider monitoring.

Common Compliance Mistakes Providers Make

Based on audit findings and inspection reports, the following are the most frequent compliance failures in this area:

1. Not enrolling learners onto functional skills at programme start. Some providers wait until the learner’s first FS session, or until the FS centre confirms enrolment, before recording the aim in the ILR. The aim should be recorded at the start of the apprenticeship programme, not weeks later.
2. Accepting self-declarations as evidence of prior attainment. A learner saying they have a GCSE at grade 4 is not the same as producing the certificate. Collect and copy certificates at sign-up.
3. Applying exceptions too broadly without adequate evidence. Providers sometimes apply the learning difficulty exception for learners who have simply struggled or failed FS, without going through a formal assessment and documentation process.
4. Not managing FS alongside the main programme. When FS is sub-contracted, it can become invisible to the main tutor. Progress reviews should explicitly reference FS status at every session.
5. Discovering gateway blockages at the final review. A learner who has not yet passed FS and has only six weeks until their planned gateway date is a crisis that was avoidable with monthly tracking. Functional skills status should be a standing RAG-rated item at every progress review.
6. Missing achievement evidence at gateway. The gateway declaration should include a specific confirmation of maths and English status — either a certificate reference number and date, or a confirmed exception record. Do not proceed to gateway without this in the learner file.

Quick Reference Checklist

• Prior attainment certificates collected and filed at programme start for all exempt learners
• ILR prior attainment field completed for exempt learners at enrolment
• Functional skills learning aims added to ILR for all non-exempt learners from programme start
• Correct Learning Aim References used for English and maths at the appropriate level
• Functional skills status — exempt, enrolled, in progress, achieved, at risk — tracked at every progress review
• Sub-contracting agreement in place with FS centre covering data reporting cadence
• Exception process documentation complete for any learner where achievement is not required
• Achievement certificates or records confirmed before gateway sign-off is initiated
• ILR achievement dates recorded promptly on confirmation from the FS centre
• Ofsted readiness: tutors can explain how English and maths are embedded in programme delivery