Five years of the funding rules: stratification, drift, and the reshaping of provider compliance in English apprenticeships, 2021–2026

Abstract

Abstract

This study presents a longitudinal documentary analysis of the apprenticeship funding rules issued by the Education and Skills Funding Agency (ESFA) for each funding year from 2021/22 to 2024/25 and by the Department for Education (DfE) for 2025/26. Drawing on all five annual funding rules documents, the analysis tracks changes in regulatory volume, complexity, conditionality, and scope. The study argues that the funding rules reveal a pattern of regulatory accumulation characteristic of policy layering, in which successive iterations add new conditions, actor categories, and compliance obligations without correspondingly removing or simplifying existing provisions. Applying theoretical frameworks from institutional change theory and the scholarship of audit culture, the analysis demonstrates that although the rules have become increasingly detailed in their specification of processes, they remain largely silent on the substantive quality of the formation of occupational competency. The study concludes that the funding rules construct apprenticeship quality primarily as compliance with procedural requirements, positioning the apprentice as a funding unit whose progress is measured against auditable milestones rather than as a learner undergoing meaningful occupational development. The implications for training providers, employers, and the apprenticeship system under the emergent Skills England regime are discussed.