Apprenticeship Behaviour Verification: What the New Government Guidance Means for Employers

Following recent apprenticeship reforms and the shift towards employer-led verification of behaviours, Skills England has published new Apprenticeship Behaviour Verification Guidance for Employers.

The guidance sets out how employers should confirm that an apprentice has demonstrated the behaviours required by their occupational standard, while removing a layer of duplicated assessment that had previously added process without improving outcomes.

This change reflects a broader move to simplify the apprenticeship system, reduce unnecessary administrative burden, and place greater trust in employers as those best positioned to observe an apprentice’s day-to-day performance. 

Rather than introducing new requirements, the reform formalises what many employers are already doing in practice, monitoring behaviours through regular supervision, feedback, and workplace interactions.

At CQM T&C, we work closely with employers to support them in navigating developments like these, helping to interpret new guidance, understand its practical implications, and embed changes effectively.

In this article, we explore what has changed, what employers should expect and the recommended guidance from Skills England.

Included in This Blog:

What are the New Apprenticeship Behaviour Verification Changes?

Who Should Verify Behaviours?

What “Consistently Demonstrated” Means

Skills England’s Recommended Apprenticeship Verification Process

Under the previous end-point assessment (EPA) model, behaviours were frequently assessed formally by an assessment organisation, in addition to the employer’s own oversight.

Under the new guidance, that duplication is removed.

The key changes are as follows:

• Employers hold primary responsibility for verifying that an apprentice has demonstrated the required behaviours.
• Assessment organisations and training providers are no longer required to separately assess behaviours or quality assure the employer’s judgement.
• Behaviours do not affect grading. An apprentice’s pass or distinction grade is determined by knowledge and skills, though behaviours must still be confirmed as sufficiently demonstrated before a certificate can be issued.
• No additional paperwork is required. The guidance is explicit that verification should be built into activity that is already standard practice for most employers: supervision, induction, feedback conversations, and regular reviews.

The overall effect is a reduction in duplication and greater trust placed in employers who are best positioned to observe an apprentice’s behaviour.

The guidance specifies that verification must come from someone, or a combination of people, who:

• work closely with the apprentice;
• has sufficient oversight of their day-to-day work to make a fair judgement; and
• understands the behaviours set out in the relevant occupational standard.

In most cases, this will be the apprentice’s line manager. Where an apprentice moves between teams, sites, or shifts, organisations should nominate the most appropriate individual.

This is the standard against which employers are asked to judge apprentices. Skills England defines a behaviour as “consistently demonstrated” when it has been:

• observed repeatedly,
• over a sustained period,
• across a range of tasks or contexts,
• in real working conditions appropriate to the level of the occupation.

In practice, this means looking for clear, consistent patterns in how an apprentice works day to day, rather than relying on one-off examples.

This new approach helps recognise real workplace performance and gives employers confidence that behaviours are genuinely embedded, not just demonstrated in isolated situations.

Skills England has set out a clear and practical approach to behaviour verification, designed to fit within your existing ways of working. 

For employers, this looks like the following:

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