Demystifying apprenticeship systems across the four nations

Apprenticeships offer people the opportunity to gain skills and qualifications while working, but the way they are structured and funded varies across the UK.

This overview looks at the apprenticeship systems in England, Scotland, Wales and Northern Ireland, including the different levels, regulators, funding arrangements and structures in each nation.

England

Levels

• Level 2 (Intermediate): Equivalent to five GCSE passes (grades 9-4/A*-C).
• Level 3 (Advanced): Equivalent to two A-level passes, NVQ Level 3 or a BTEC.
• Level 4 & 5 (Higher): Equivalent to a foundation degree, HNC or HND.
• Level 6 & 7 (Degree): Equivalent to a Bachelor’s (Level 6) or Master’s degree (Level 7).

The new Growth & Skills Levy, launched in April 2026, allows employers to use levy funding for a broader range of training, including shorter, more flexible training units alongside apprenticeships.

Regulator

Ofqual (Office of Qualifications and Examinations Regulation) leads on the quality and standards of End-Point Assessments (EPAs).

Skills England oversees the apprenticeship system.

Funding

Strategic direction and funding rules transferred from the Department for Education to the Department for Work and Pensions.

Structure specifics

• England uses ‘Employer’s Standards’.
• Employers with an annual employment pay bill above £3 million pay the levy, while smaller employers share costs.
• England moved in 2026 from a minimum duration of 12 months to eight months, like in Scotland.
• With the new Growth and Skills Levy, large levy-paying employers lost the 10% top-up on their funds, face a shorter 12-month expiry window, and must pay 25% of training costs once their levy pot runs out.
• Apprenticeships for 16-to-24-year-olds in England are fully government-funded from 2026, with the government paying the full cost of training and assessment.

Scotland

Levels

• Foundation Apprenticeships (SCQF Levels 5–6): Designed for S5/S6 school pupils to gain skills and work experience alongside their National 5s and Highers. This is equivalent to two Highers. Foundation Apprenticeships are currently under review. The schools work experience option will remain, but the title is yet to be decided.
• Modern Apprenticeships (SCQF Levels 5–7+): Aimed at those aged 16 and older, allowing them to gain qualifications while in paid employment, often focusing on industry-specific competencies.
• Graduate Apprenticeships (SCQF Levels 8–11): Enable individuals to work, earn a salary and complete a degree, including Bachelor’s and Master’s degrees.

Regulator

Skills Development Scotland (SDS) manages the apprenticeship programme and publishes rules for Foundation and Modern Apprenticeships.

The Scottish Apprenticeship Advisory Board (SAAB) offers industry-led advice to the Scottish Government to ensure the system meets employer needs. It also approves new and amended standards and frameworks for Modern Apprenticeships.

SAAB will no longer exist from April 2027 and will be replaced by the Apprenticeship Committee and Sub Committee, governed by the Scottish Funding Council, which will assume the functions of SAAB.

Qualifications Scotland (formerly SQA) Accreditation accredits the main competency qualifications that form part of Apprenticeship Standards.

Sector Skills Councils (SSCs) support SDS in the development of apprenticeship frameworks and standards content.

From April 2027, apprenticeship standards and frameworks approval and content will be the responsibility of the Scottish Funding Council.

Funding

Responsibility for funding national training programmes and apprenticeships will move from Skills Development Scotland to the Scottish Funding Council in April 2027, to better integrate colleges, universities and work-based learning.

Structure specifics

• Scotland uses Scottish Vocational Qualifications (SVQs) and Competency Based Qualifications (CBQs), plus enhancements. These form the basis for frameworks and Modern Apprenticeships.
• Employers with an annual employment pay bill above £3 million pay the levy, while smaller employers share costs.
• Apprenticeships in Scotland are funded through a contribution rate system rather than a direct levy return.
• The minimum duration of apprenticeships is eight months.
• Fully funded training for 16-to-24-year-olds is primarily delivered through Modern Apprenticeships under the Guarantee Group. Adult apprentices are also funded at a reduced contribution rate for those who meet the guaranteed group age criteria.

Wales

Levels

• Foundation (Level 2): Equivalent to five GCSEs.
• Apprenticeship (Level 3): Equivalent to two A-levels.
• Higher (Levels 4-7): Equivalent to HNC/HND up to Master’s.
• Degree (Level 6): Combines work with university study for a Bachelor’s degree.

Regulator

Qualifications Wales regulates qualifications in Wales.

Medr (the Commission for Tertiary Education and Research) oversees the tertiary education and training system in Wales.

Funding

The Welsh Government often funds 100% of training costs for eligible apprentices, including those aged 16-24 who are Welsh residents.

Employers with an annual employment pay bill above £3 million pay the levy, while smaller employers share costs.

Structure Specifics

• Wales uses ‘Apprenticeship Frameworks’, which are models with tailored pathways approved by the Welsh Government, compared with England’s ‘Employer Standards’.

Northern Ireland

Levels

• Level 2 Apprenticeships: Designed for those starting out and equivalent to five GCSE passes.
• Level 3 Apprenticeships: Equivalent to two A-level passes; some sectors may require previous experience.
• Higher Level Apprenticeships (HLAs) (Levels 4–7): Equivalent to HNCs, HNDs, foundation degrees, or full undergraduate/postgraduate degrees.

Regulator

The Council for the Curriculum, Examinations and Assessment (CCEA) is responsible for qualifications, examinations and assessments in Northern Ireland.

The Department for the Economy (DfE) oversees the apprenticeship system.

Funding

Employers with an annual employment pay bill above £3 million pay the levy, while smaller employers share costs.

The Northern Ireland Government covers 100% of off-the-job training costs for apprentices aged 16-24.

Structure specifics

• Northern Ireland uses framework-based models with tailored pathways.
• Training is delivered through specific industry-approved frameworks that include a competency-based qualification (NVQ).
• The minimum 12-month requirement was reduced to eight months from 2026.
• There is also a requirement to be contracted to work at least 21 hours per week with a Northern Ireland-based employer.
• Northern Ireland remains the only UK region that largely excludes public sector bodies from apprenticeship funding.

Apprenticeships across the four nations

While apprenticeships across the UK share the same broad aim of combining employment with learning, the systems differ depending on where an apprenticeship is undertaken.

The levels, regulators, funding arrangements and structures vary across England, Scotland, Wales and Northern Ireland. Understanding these differences can help employers and individuals navigate the options available to them.

This overview is part of a mini series brought to you by The Policy Centre for Supply Chain and SMEs: Powered by Enginuity.

Find out more about apprenticeships