Off-the-Job Training Hours: What Counts, What Doesn't, and How to Track It

What Is Off-the-Job Training?

Off-the-job (OTJ) training is a statutory requirement for all apprenticeships in England. The ESFA definition is specific:

"Learning activities, carried out outside of normal working duties, during the apprentice's normal working hours, that are directly relevant to the knowledge, skills and behaviours in the apprenticeship standard."

Two phrases in that definition do a lot of work.

"Outside of normal working duties" — if the apprentice would be doing this task whether or not they were on an apprenticeship, it doesn't count. OTJ is learning, not work.

"During normal working hours" — OTJ must happen within contracted working time. Activities outside contracted hours, including study in personal time, do not count toward the 20% requirement.

The 20% Rule Explained

All apprenticeships must include at least 20% of the apprentice's contracted working hours as off-the-job training across the duration of the programme.

The formula is: (Contracted weekly hours × Total working weeks) × 20%

Where total working weeks = programme duration in weeks, minus holiday entitlement expressed in weeks.

Worked Example

• Apprentice contracted: 37.5 hours per week
• Programme duration: 18 months (78 weeks)
• Annual leave entitlement: 28 days = 5.6 weeks
• Working weeks: 78 − 5.6 = 72.4 weeks
• OTJ target: 37.5 × 72.4 × 20% = 543 hours

This target must be met across the full programme duration — it's not a per-month or per-quarter requirement, though it's best practice to track progress monthly.

What Counts as Off-the-Job Training?

The ESFA provides guidance on qualifying activities. These count:

Training delivered by the employer in the workplace — but only where it is specifically for the apprenticeship and involves learning that is separate from normal day-to-day duties. A structured internal training session designed for the apprenticeship qualifies. Informal instruction as part of getting the job done does not.

Training delivered by the training provider — college sessions, online learning modules, webinars, workshops, face-to-face lessons.

Learning support activities — writing assignments, building a portfolio of evidence, preparing for assessments, completing reflective journals.

Conferences and industry events — where the learning is directly relevant to the standard and structured (not networking or attendance at a general industry event).

Shadowing — structured observation of other workers that is designed to build competency in a specific KSB area.

Mentoring sessions — time in structured mentoring where learning and development is the explicit focus (not informal management conversations).

Industry visits and study trips — where learning is the primary purpose.

English and maths provision — if the standard requires Level 2 English and maths, time spent on this counts as OTJ.

End-Point Assessment preparation — including mock assessments, revision sessions, EPA briefings, and interview preparation.

Online and self-directed learning — provided it is structured, tracked against the standard, and mapped to specific learning outcomes.

What Does NOT Count?

This is where most compliance failures occur.

Normal day-to-day work activities — even if directly related to the apprenticeship standard. A software developer apprentice writing code as part of their job is doing their job, not OTJ training. If the same activity were structured as a learning exercise with specific KSBs in mind and separate from their deliverables, it might qualify — but it needs to be deliberate and documented.

Annual leave and bank holidays — time off does not count, even if the apprentice uses it to study.

Breaks and lunch — time outside contracted working hours cannot be counted.

Overtime — hours beyond the contracted working week do not count.

General workplace induction — health and safety inductions, HR paperwork, IT setup. These are employment requirements, not apprenticeship training.

Mandatory employment training — training the employer requires regardless of the apprenticeship (e.g., mandatory health and safety courses for all staff). These are employer obligations, not apprenticeship learning.

Sick leave and absence — periods of absence reduce available OTJ time and may require the programme end date to be extended.

Common Mistakes That Create Audit Risk

Blanket logging

Logging "training — 8 hours" every week without describing what was actually learned is an audit red flag. ESFA auditors look for specificity. What was the learning activity? What skills or knowledge did it address? Which part of the standard did it relate to?

Not tracking cumulatively

OTJ is a whole-programme measurement, not a monthly one. Providers who track OTJ completion in isolation sometimes miss that a learner is on track each quarter but behind cumulatively because of a period of absence or an employer who stopped releasing them for training.

Employer not signing off

Best practice is for both the apprentice and the employer supervisor to sign off OTJ records. Unsigned records have weaker evidential value in a funding audit. If challenged, unsigned logs are far easier to dispute.

Confusing OTJ with total learning

OTJ is the 20% learning component. The remaining 80% is the work-based learning — the job itself. These are distinct. Total learning hours (OTJ + work-based) should add up to the apprentice's contracted hours over the programme.

Best Practice for OTJ Tracking

1. Calculate the target at sign-up

At the start of every programme, calculate the exact OTJ target for each apprentice based on their specific contracted hours and programme length. This number becomes the benchmark.

2. Log weekly, review monthly

Weekly logging is more accurate and produces better evidence than monthly retrospective logging. Monthly review of cumulative progress catches drift early.

3. Describe the activity, not just the duration

Every log entry should include: date, description of the learning activity (specific enough to match a KSB or standard element), duration, and sign-off from both the apprentice and employer contact.

4. Track RAG status at every review

At each progress review, show the OTJ RAG status:

• Green: on track — cumulative OTJ meets or exceeds the expected percentage through the programme
• Amber: slightly behind — catch-up plan needed
• Red: significantly behind — programme extension may be required

5. Address red status early

If a learner falls significantly behind, work with the employer to understand why and create a formal catch-up plan. In some cases the programme end date needs extending — this is far preferable to arriving at EPA gateway with insufficient hours.

6. Retain records for funding audit

ESFA can request OTJ records as part of a funding audit at any point during or after the programme. Records should be kept for at least 3 years after completion.

OTJ Hours at EPA Gateway

Before signing a learner off for EPA, confirm each of these:

• Total OTJ hours logged meet or exceed the 20% target for this specific apprentice
• All logs are descriptive and activity-specific (no blanket "training" entries)
• Employer supervisor has signed off on OTJ records
• Any periods of absence, furlough, or reduced hours are documented and the programme end date adjusted if required
• Logs cover the full programme duration without unexplained gaps
• Evidence is retained and accessible for potential ESFA audit

Frequently Asked Questions

What if an apprentice works part-time?

The 20% rule applies to contracted working hours — not a fixed number. A part-time apprentice working 20 hours per week has a lower OTJ target (20% of their total contracted hours over the programme), but the proportion is the same.

Can OTJ happen at the employer's premises?

Yes. OTJ can take place at the employer's site, at the training provider's site, online, or at a third-party venue. Location doesn't determine whether it qualifies — the nature of the activity does.

Does COVID furlough affect OTJ requirements?

Periods of furlough should be excluded from OTJ calculations. The programme should be extended by the length of the furlough period. Providers should keep records of any furlough periods and programme extensions.

What happens if a learner doesn't meet the 20%?

The learner cannot pass through EPA gateway until OTJ requirements are met. In some cases this means extending the programme. ESFA can also claw back funding for apprenticeships where OTJ evidence is inadequate.