Working with employers on reasonable adjustments for apprentices

An apprentice spends most of their week at work. However good the provider’s support plan, it will not help much if the workplace is where the barrier sits. Yet many providers find employer conversations about adjustments the hardest part of the job: the employer is busy, the apprentice is nervous about being seen as a problem, and the provider is caught between them holding sensitive information.

This guide sets out a practical way to work with employers on adjustments that respects the apprentice, gets the workplace part done and keeps a clear record. It explains duties and good practice; it is not legal advice.

Who is responsible for an apprentice’s reasonable adjustments, the employer or the provider?

Each party owns the part of the apprenticeship it controls.

Two details shape the provider’s role.

First, an employer is not under the duty if it does not know, and could not reasonably be expected to know, that the apprentice is disabled and likely to be disadvantaged (Schedule 8, paragraph 20). The provider often learns about a disability first, at initial assessment. That makes the provider a bridge, but the apprentice decides what crosses it.

Second, money flows differently. The provider can claim learning support funding for training adjustments. The employer pays for workplace adjustments and can get help through Access to Work. The DWP guidance says employers should not use learning support to make or fund workplace adjustments. See Access to Work for apprentices.

What should you share with an employer?

Share the minimum the employer needs to act, with the apprentice’s agreement. Health and disability information is special category data under UK GDPR, which needs both a lawful basis and an additional condition, and extra care (ICO guidance). In practice, most employers need much less than providers assume.

The funding rules reflect this. Where you claim learning support, the delivery plan is shared with the employer if the apprentice consents. For additional payments for 19 to 24 year olds, you need consent before telling the employer about an EHC plan or care history.

Ask the apprentice how they want it described. “Needs written instructions and a quiet space for focused work” may be all the employer needs to hear, without any label at all. The employer adjustments summary template gives a one-page format.

How do you have the first conversation?

Prepare with the apprentice first, then meet the employer, ideally together.

Before the meeting, with the apprentice:

1. Agree what they want the employer to know, in their own words.
2. Agree the workplace adjustments to ask for, and which matter most.
3. Agree whether they want to be in the meeting, and what they would like you to say if they are not.

In the meeting, with the employer:

1. Start with the job. What does the apprentice need to do, and where do they find it hard?
2. Present adjustments as ways to help them do the job well, not as favours.
3. Agree specific actions, an owner for each and a date.
4. Mention help available, such as Access to Work, and the employer’s possible costs.
5. Agree how the employer will tell you if something is not working.

After the meeting:

1. Send a short written summary of the agreed actions to the employer and the apprentice.
2. Add them to the apprentice’s plan.
3. Check them at the next progress review.

Fictional example. Sam, 24, is a level 4 software developer apprentice with anxiety and dyslexia. Sam is comfortable with the employer knowing about the dyslexia but not the anxiety. The provider and Sam agree to ask for three adjustments: meeting agendas sent in advance, permission to use speech-to-text software, and written feedback on code reviews. The provider’s summary to the employer lists those three actions and a review date, with no mention of anxiety. At the next review, Sam says the written feedback helps most and asks whether the team’s daily stand-up could be held at the same time each day. The provider adds that request to the summary, with Sam’s agreement.

What if the apprentice does not want the employer told?

Respect it. Disclosure is the apprentice’s choice. Many apprentices worry about being judged or losing their job, especially early on. You can still:

• make every training adjustment that does not depend on the employer
• explain, without pressure, what the employer cannot be expected to do if they do not know
• explain that Access to Work will not contact the workplace without permission, but workplace support usually needs the employer’s involvement
• revisit the decision at each review

If you believe there is a safeguarding risk, follow your safeguarding procedures. That is a separate process with its own rules on sharing.

How do you keep adjustments on track?

Use the routines you already have. Most apprenticeships include regular progress reviews with the apprentice and employer. Make adjustments a standing item:

• Are the agreed workplace adjustments happening?
• Are the training adjustments happening?
• Ask the apprentice first: is each one helping?
• Keep, change or stop each one, and record the decision.

Where you claim learning support, the funding rules require you to review the support at least every 3 calendar months, with changes signed off by the apprentice. A shared review keeps the workplace and training sides in step. Our guide to reviewing whether support worked has question prompts.

The 2025 to 2026 assessment reforms give employers a bigger role in verifying behaviours, and assessment may happen at any stage of the apprenticeship. That makes it more important that employers understand adjustments that affect how the apprentice is observed or assessed at work. See reasonable adjustments in end-point assessment.

What if a new need appears at work?

Sometimes the employer spots a difficulty before anyone else: missed instructions, lateness, mistakes in written work, or an apprentice who seems overwhelmed. Employers often raise this as a performance issue. Encourage them to raise it with you early, and to talk to the apprentice before drawing conclusions.

When it happens:

1. Talk to the apprentice privately first. Ask what is going on and what would help.
2. If a disability or learning difficulty may be involved, offer screening or further assessment through your learning support team.
3. Agree with the apprentice what to tell the employer.
4. Agree interim adjustments quickly, rather than waiting for a full assessment.
5. Record the new need, the adjustments and the review date in the plan.

The funding rules recognise that a need may not have been identified at the start. Where it directly affects the apprentice’s ability to complete, learning support can apply from the date evidence is acquired.

What if an employer will not make an adjustment?

Start by understanding why. Common reasons are cost, worry about fairness to other staff, and not understanding the need. Each has an answer:

• Cost. Explain Access to Work, which may fund support beyond the employer’s legal duty and contributes to equipment costs. Many adjustments cost little or nothing.
• Fairness. Adjustments remove a disadvantage; they are not an advantage. Treating the apprentice identically can be unlawful where it puts them at a substantial disadvantage.
• Understanding. Offer a short briefing for the line manager, with the apprentice’s agreement.

If the employer still refuses an adjustment that seems reasonable, record the conversation, raise it within your organisation, and make sure the apprentice knows where to get independent advice. Do not give legal advice yourself. If the relationship breaks down, the apprentice’s welfare and progress come first.

How should providers prepare employers in advance?

The best time to talk about adjustments is before an apprentice needs them. Build it into employer onboarding:

• a short explanation of reasonable adjustments and Access to Work in your employer pack
• a clear statement of what the provider will share and what it will not
• a named contact for adjustment questions
• an agreement that adjustments will be a standing item in progress reviews

Employers who have heard this once at the start respond far better when an individual case arises. Our employers role page summarises what an employer contact needs to know. Supporting employees more widely is a different job; a workplace inclusion edition is planned for later and is not part of the pilot.

How does Inclusion Studio support this process?

Inclusion Studio is learner support software being built for FE colleges and apprenticeship providers in England, currently pre-pilot with a prototype using fictional learners. Employer collaboration is designed so an employer contact sees only the workplace adjustments and their own actions for the apprentice they are linked to, never the learner’s full history, with permissions enforced on the server by organisation, relationship and field. The apprentice’s support plan and reviews sit with the provider. The employer and provider remain responsible for their own legal duties.