Guidance Guidance for apprentices, employers, training providers, end-point assessment organisations (EPAOs) and external quality assurance providers about changes to apprenticeships due to coronavirus (COVID-19)
Apprenticeship training frequently asked questions
As an employer how will I know if I need to top up an employee’s wages if they are furloughed but continuing with their apprenticeship?
Where training is undertaken by furloughed employees, at the request of the
employer, they are entitled to be paid at least their appropriate National
Minimum Wage for this time. In most cases, the furlough payment of 80% of an
employee’s regular wage, up to the value of £2,500, will provide sufficient
monies to cover these training hours. However, where the overall time spent
training during the furlough period, attracts a minimum wage entitlement in
excess of the furlough payment, employers will need to pay the additional
wages. This is because time spent training is treated as working time for the
purposes of the minimum wage calculations, and therefore must be paid at the
appropriate rate, taking into account the increase in minimum wage rates from
1 April 2020.
Employers should consider the hours that an employee is expected to train
during the period of the furlough (which must be a 3-week minimum). Employers
will need to ensure that the furlough payment provides sufficient monies to
cover these training hours. Where the entire furlough payment equates to less
than the appropriate minimum wage entitlement for the training hours during
the furlough period, the employer will need to pay the additional wages to
ensure at least the appropriate minimum wage is paid for the time spent
training.
Our worked examples show how to calculate whether the furlough payment equates
to less than the appropriate minimum wage entitlement for time spent training.
Example 1:
18 year old first year apprentice is on a 37 hours per week contract and has
been furloughed. They are continuing to train for 1 day per week (7.5 hours
per week).
In terms of the National Minimum Wage (NMW) regulations they are entitled to
£4.15 for every hour they train. (Note that the NMW legislation does not apply
to time not in work or training.)
Over the 3 week furlough period (the pay reference period) this amounts to an
NMW entitlement of £93.38 (£4.15 x 7.5 hours x 3 weeks).
The 80% furlough payment that they have received from their employer is £368.
This furlough payment provides sufficient money to cover these training hours.
Example 2:
22 year old second year apprentice is on a 37 hours per week contract and has
been furloughed. They have agreed, with their employer and provider, to train
for 4 days per week (7.5 hours per day) (to cover as much off-the-job training
as possible during this period).
In terms of the National Minimum Wage regulations they are entitled to £8.20
for every hour they train. (Note that the NMW legislation does not apply to
time not in work or training.)
Over the 3 week furlough period (the pay reference period) this amounts to a
NMW entitlement of £738 (£8.20 x 7.5 hours x 4 days x 3 weeks).
The 80% furlough payment that they have received from their employer is
£728.16. This furlough payment does not provide sufficient money to cover
these training hours and the employer would need to top up the difference
(£9.84).
Note in both cases above the apprentice, prior to furlough, was paid at/close to the National Minimum Wage.
  [NMW]: National Minimum Wage