NFRC Joins Coalition of Organisations Pushing Back on Proposals to Strip Back Apprenticeship Standards

Announcements from Skills England have sparked concerns that apprenticeship reforms are set to reduce competency requirements and the diligence of testing. This concerning, especially given the great strides industry has made in recent years towards upping standards, alongside preexisting concerns around the streamlining of apprenticeships.

NFRC has now contacted the Skills Minister, the Department for Work and Pensions, and Skills England to express these concerns, but we encourage our Members to also contact their local MPs. Please contact [email protected] if you wish to help.

The details of the proposed reforms and our thoughts are included below in a version of the letter we have sent to government.

“NFRC supports efforts to improve the apprenticeship system, reduce unnecessary burden, and ensure assessments remain proportionate. However, we have serious concerns regarding the proposed reforms to apprenticeship assessment, the pace at which changes are being implemented, and the potential unintended consequences for safety-critical, skilled craft occupations such as roofing and cladding.

1. The reforms mark a significant departure from the system employers were assured would raise quality

According to the government’s published aims, the reforms seek to:

• Make assessment more proportionate and remove duplication
• Enable assessment throughout the programme
• Permit training providers to mark elements of the assessment
• Retain the role of assessment organisations in validating outcomes

While these aims appear reasonable at headline level, the practical implications represent a return toward the old apprenticeship framework model, a model that was previously criticised for inconsistency, variable quality, and low employer confidence during the Richard Review. 

Continuous assessment

Allowing assessments to take place throughout the apprenticeship risks re-introducing the issues that standards were designed to fix. Roofing employers remember that NVQ-driven continuous assessment did not always ensure robust, independent testing, contributing to poor completion and retention outcomes.  

Provider-marked assessments

We are particularly concerned by proposals enabling training providers to mark elements of the assessment. Under the previous framework system, employers consistently reported:

• Variability in assessor competence
• Inconsistent interpretation of requirements
• Concerns that commercial pressures could compromise rigour

The apprenticeship reforms were introduced precisely to strengthen independence and quality. Re-introducing provider marking risks undermining employer confidence again.

2. The reduction of mandatory skills and introduction of “sampling” pose risks in safety-critical trades (like roofing and cladding)

Initial reports indicate a 30–40% reduction in mandatory skills and processes assessed and the use of sampling, meaning only around 40% of KSBs would be mandatorily assessed for every apprentice. For roofing, the current Level 2 Roofer apprenticeship contains 39 KSBs, comparable with other construction trades. A 30–40% reduction would mean 12–15 fewer KSBs being assessed across all learners, with only a sample of apprentices assessed against the full set.  

Roofing and cladding work involves:

• Working at height
• The installation of weather-tight systems
• Technical detail
• Adherence to tolerances and standards

These are not optional skills. They cannot safely be reduced or partially assessed.

We also note concerns raised in the sector press that AI-driven systems could determine which skills remain. We have found no official confirmation of this but would welcome urgent clarification.

3. Shortening minimum apprenticeship duration to eight months risks undermining competence and employer confidence

From August 2025, minimum duration will fall from 12 to 8 months. While some sectors may welcome this, roofing employers are deeply concerned. Roofing is a practical, hands-on craft requiring time for:  

• skill development
• repetition
• judgement
• working safely in real-world conditions

The move to standards was intended to increase, not reduce, confidence that an apprentice has had sufficient time to grow into a competent tradesperson. Would you be comfortable with a “qualified” apprentice working on your roof with 8 months experience? Currently they would have 2 years' experience at a minimum before being able to work unsupervised.

4. Transferring responsibility for behaviours to employers requires clarity and support

The reforms propose that employers will verify behavioural competence.

While employers understand the behaviours required (including teamwork, safety culture, professionalism) they will need clear guidance, tools, and support to avoid inconsistency and to reduce burden, especially for SMEs.

NFRC is ready to support the development of such guidance, but at present, we cannot identify how Skills England is coordinating this with sectors. We have not yet received communication from the listed Skills England product manager for roofing.

5. The rapid review process lacks adequate sector consultation

Reports of compressed consultation times and poor engagement are deeply concerning. Roofing employers are committed to ensuring apprenticeship quality and have always engaged constructively in reviews, however, the current process does not appear to provide opportunities for meaningful input.

Given the safety-critical nature of roofing, lack of consultation is unacceptable.

6. Digital assessment, removal of tolerances, and changes to EPA guidance need careful scrutiny

Digital assessment is a welcome ambition but must be deliverable and appropriate for practical trades. Removal of tolerances risks eliminating essential industry standards that ensure safe, acceptable workmanship. EPA guidance reduced to two pages seems unrealistic unless supported by additional materials, otherwise quality and clarity will suffer.

Our Requests

We urge Skills England to pause and review the implementation of these reforms for safety-critical construction apprenticeships until the following conditions are met, as well as to provide:

• Clear evidence that proposed reductions in assessment and duration will not compromise safety or competence
• Meaningful consultation with employers, professional bodies, and assessment organisations. Please also confirm whether the roofing apprenticeship is included in review group one, two, or three
• Clarity on the respective roles of Skills England, training providers, employers, and EPA organisations
• Sector-specific assurance that sampling, compressed duration, and provider-marked elements will not re-create the failings of the previous apprenticeship framework system

• Assurance that Skills England has ascertained if they are now in breach of the A move away from allowing end point assessment organisations to develop their own end point assessment process, as this leads to a race to the bottom to rush learners through and draw down funding whilst trying to demonstrate they are increasing numbers on programme

• Institute for Apprenticeships and Technical Education (Transfer of Functions etc) Act by creating the end point assessment plans, as employers did not develop the proposed assessment plan
• Correction of the situation whereby the new approach has actively removed industry involvement, meaning that the apprenticeship assessment plans are exempt from industry input. We ask that this situation is corrected
• Government suspension of the application of the proposed apprenticeship reforms and active engagement with all industries to help increase the competence of individuals
• Reinstatement of the allowance of tolerances in the assessment plan, especially when this comes to practical trades and working with life-safety-critical products
• Permission for trailblazers and industry to set the mandatory requirements within the assessment plan and increase the 30/40% ruling where it is impossible to match this for demonstrating an individual’s competence, especially when working with life-safety-critical products

NFRC and our members remain committed to delivering high-quality training that strengthens the roofing industry and keeps workers and the public safe. We stand ready to work with Skills England to ensure any reforms support, not undermine, these aims."