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On March 9, the U.S. Department of Labor’s Employment and Training Administration announced four new guidance documents on the implementation of registered apprenticeship programs. The stated goal of the guidance is to improve flexibility and reduce burdens for program sponsors, promote clarity and consistency in the registration process across states, elevate quality standards and increase transparency.

 

The guidance documents are:

  • Circular 2026-01—Provides updated guidelines for registered apprenticeship program design, improving flexibility for program design
    • Rescinds the 12-month on-the-job learning minimum for competency-based programs
    • Rescinds the 25% limit on adjustment of hybrid or time-based programs
    • Rescinds the maximum credit limitation for prior experience at 50% of training
    • Clarifies that 144 hours of related instruction per year of apprenticeship is recommended but not required
    • Rescinds the requirement for certificate of completion that the apprentice had worked for the program sponsor as a registered apprentice in the occupation for at least six months/1,000 hours

 

  • Circular 2026-02—Clarifies the roles of state apprenticeship agencies and apprenticeship councils, seeking to prevent excessive delegation to SACs
    • Prohibits SACs from evaluating/registering apprenticeship standards or programs, making apprenticeability decisions or deregistering programs

 

  • Circular 2026-03—Sets out a standardized completion rate calculation and announces a new performance data portal

 

  • Bulletin 2026-35—States the DOL’s commitment to timely registration determinations
    • The DOL commits to making determination within 30 days of submission
    • Announces new “shot clock” website to share number of programs registered and average time to register

 

“ABC strongly supports the DOL’s bold new approach to addressing longstanding concerns with registered apprenticeship programs by improving flexibility for program sponsors and employers, as well as addressing state policies that impair worker access to these high-quality training programs," said ABC Vice President of Government Affairs Kristen Swearingen in a statement. "These policies align with our consistent advocacy for simplification of unnecessarily burdensome apprenticeship regulations, and ABC thanks the DOL for taking steps to implement our recommendations."

Overall, the guidance represents a welcome new approach to expanding RAPs by easing access for employers and sponsors and emphasizing the need for flexibility. RAPs are a critical component of ABC’s all-of-the-above approach to workforce development, with ABC chapters offering over 450 RAPs across the country. ABC looks forward to continuing to partner with the DOL on efforts to address the construction industry’s ongoing workforce shortage.

 

DOL will also be hosting a webinar discussing the guidance on March 27. Register for the webinar on WorkforceGPS.



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