Reasonable adjustments for apprentices

An apprentice is a learner and an employee at the same time. That makes reasonable adjustments more complicated than in a classroom: the training provider, the employer and the assessment organisation all have duties, and each controls different parts of the apprentice’s week. When nobody owns the whole picture, adjustments fall into the gaps, most often at work and at the final assessment.

This guide explains who owes what, how to agree adjustments with the apprentice, how funding fits in, and how to keep everyone aligned without oversharing. It explains duties and good practice; it is not legal advice.

Do apprentices have a right to reasonable adjustments?

Yes. A disabled apprentice is protected by the Equality Act 2010 as an employee, as a learner and as a candidate for assessment. The core duty in section 20 has three requirements. Where a disabled person would be at a substantial disadvantage compared with non-disabled people, take reasonable steps to:

1. change a provision, criterion or practice (a rule, policy or way of doing things)
2. remove or alter a physical feature, or provide a way to avoid it
3. provide an auxiliary aid or service, such as equipment, software or a support worker

Where information is involved, reasonable steps include providing it in an accessible format. Section 20(7) also says you cannot require the disabled person to pay for the adjustment.

“Disabled” here is the legal definition: a physical or mental impairment with a substantial and long-term adverse effect on normal day-to-day activities. Many apprentices who are dyslexic, autistic, have ADHD, a mental health condition or a long-term health condition will meet it. They do not need a diagnosis or a label to be protected, although evidence helps everyone agree what will help. For the wider legal picture, see our Equality Act 2010 guide for FE providers.

Who must make reasonable adjustments for an apprentice?

Three parties, each for its own part of the apprenticeship.

Two differences matter in practice.

When the duty starts. For colleges, the duty in further education is owed to disabled students generally (Schedule 13, paragraph 3), so you should anticipate common needs before a learner arrives. An employer is not under the duty if it does not know, and could not reasonably be expected to know, that the person is disabled and likely to be disadvantaged (Schedule 8, paragraph 20). In practice, that means the provider often knows first, and the apprentice decides whether the employer is told.

Who pays. The provider pays for training adjustments and may be able to claim learning support funding. The employer pays for workplace adjustments and may get help through Access to Work. The DWP guidance is explicit: employers should not use learning support to make or fund workplace adjustments.

Which adjustments help apprentices most often?

The best adjustment is the one the apprentice says works, tested in practice. Starting points by area:

Off-the-job training

• materials in advance, in an accessible format, with plain-English summaries
• recorded or captioned sessions, and permission to use recording tools
• breaking long assignments into checkpoints with feedback
• assistive technology such as text-to-speech, speech-to-text or mind-mapping software
• flexible timing of off-the-job hours where the employer agrees

Progress reviews and assessor visits

• agenda sent in advance, shorter and more frequent reviews
• a quiet, private space, at a predictable time
• written summary of actions after each review

The workplace

• written or visual task lists, and one clear point of contact
• adjusted start times, rest breaks or a phased start
• noise-reducing headphones or a quieter desk
• equipment and support workers, often with Access to Work funding

Assessment

• extra time, rest breaks, a reader or scribe, a separate room
• questions given in writing as well as verbally
• assistive technology the apprentice already uses

Use the adjustment ideas finder for more examples by need. Always ask the apprentice before assuming an idea will suit them.

How do you agree adjustments with an apprentice?

Start with a conversation, not a form. A good process has five steps.

1. Screen at initial assessment. The funding rules require a screening exercise for learning support as part of initial assessment. Ask open questions about what has helped before, at school, college or work.
2. Understand the barrier. If screening suggests a need, carry out a further assessment. Focus on what the apprentice finds hard in this apprenticeship and why.
3. Agree a plan with the apprentice. Write down each adjustment, who delivers it, where, and how you will know it is helping. Where you claim learning support, the funding rules require a delivery plan agreed and signed off by the apprentice.
4. Agree what the employer needs to know. Ask the apprentice what they are happy to share. Share only the workplace adjustments and the employer’s actions, not the full history.
5. Review at least every 3 months. Ask the apprentice whether each adjustment helped, then keep, change or stop it. Record the decision.

Fictional example. Dan, 19, is an autistic level 2 warehouse apprentice. In his first review he says the noise of the warehouse floor makes it hard to concentrate in on-site coaching sessions, and verbal instructions from different supervisors conflict. The provider moves coaching to a quiet office, sends the agenda by text the day before, and records it in his plan. With Dan’s agreement, the provider shares two workplace actions with his employer: one named supervisor for daily instructions, and a written shift task list. At the next review Dan says the task list helps but the office is still noisy at lunchtime, so the coaching time moves.

The reasonable adjustments agreement template and the employer adjustments summary help with steps 3 and 4.

What should the employer be told?

Only what they need to make the workplace adjustments, and only with the apprentice’s agreement. Disability and health information is special category data under UK GDPR, so treat it carefully. Two funding rules also turn on consent:

• the learning support delivery plan is shared with the employer if the apprentice consents
• for additional payments for 19 to 24 year olds, you need the apprentice’s consent before telling the employer about an EHC plan or care history

If the apprentice does not want the employer told, respect that, explain what the employer cannot then be expected to do, and keep the conversation open. Our guide to working with employers on adjustments covers how to have that discussion and what to put in writing.

How do adjustments carry into the apprenticeship assessment?

They do not carry over automatically. The assessment organisation decides adjustments for the apprenticeship assessment under its own reasonable adjustments policy, and usually needs evidence and notice. The terminology changed during the 2025 to 2026 reforms: “apprenticeship assessment” and “assessment organisation” replace “end-point assessment” and “end-point assessment organisation” for revised standards, although the older terms still apply to standard versions not yet revised.

Your best evidence is a record of what the apprentice used during training and whether it worked. Plan this from the start, not at the gateway to completion. See reasonable adjustments in end-point assessment.

What about English and maths?

There is a specific flexibility. Where a learning difficulty or disability is a barrier to the usual English and maths requirements, an apprentice may be able to achieve Entry Level 3 functional skills instead. The funding rules require an existing or previous EHC plan (or legacy statement or learning difficulty assessment), or a formal, evidence-based assessment by an appropriate professional. Self-declaration is not enough. If the apprentice disputes the decision, you must offer a second opinion from a second SEN professional. Even where the flexibility applies, you are still expected to support the apprentice’s English and maths development. Adjustments to off-the-job training should be agreed and recorded like any other.

What are the most common mistakes?

• Assuming the employer knows. They often do not, and the apprentice may not have told them.
• Sharing too much. Sending a full diagnostic report when the employer only needs two actions.
• Agreeing adjustments and never checking them. A plan is not evidence that support happened.
• Leaving assessment adjustments to the last month. The assessment organisation may need weeks of notice.
• Paying for workplace adjustments from learning support. The guidance says this is the employer’s cost.
• Treating “reasonable” as “affordable for us”. Reasonableness weighs effectiveness, practicability, cost, resources and available help. Funding and Access to Work count as available help.

How does Inclusion Studio support this process?

Inclusion Studio is learner support software for FE colleges and apprenticeship providers in England, currently at pre-pilot stage with a prototype using fictional learners. It is designed around the steps above: capture the apprentice’s own view of what helps, agree a support plan they have seen, and record delivered and missed support. Employer collaboration is designed so an employer contact sees only the workplace adjustments and their own actions, never the apprentice’s full history, with permissions enforced on the server. The provider and employer remain responsible for their legal duties. See how it fits apprenticeship providers.