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Subcontracting Policy 2026/27

Subcontracting Policy – 2026/27

Apprenticeships and Adult Skills Funding

Policy Details
Policy Owner:Director of Apprenticeships and Business Solutions
CE Sponsor:Deputy Principal
Date created:22nd June 2026
Version:Approved by:Date approved:To be reviewed:
4College Executive25 June 2026June 2027
4Finance and Resource Committee2 July 2026July 2027
In Year Updates
Version:Date of Interim Review Date approved by CE Sponsor:
4.1

 

Version Control
Version NumberChanges
2Changes made in line with updated funding rules (July 2025). In the main this includes the new £100,000 threshold that enables us to subcontract to providers that are not on the Apprenticeship Provider Assessment Register.
2Updated the list of subcontractors.
2Included links to the relevant funding rules and updated LSIP link.
Changes to policy in year
3Following the closure of the ESFA on 31 March 2025, all subcontracting references now refer to the Department for Education (DfE).
3Only providers on the Apprenticeship Provider and Assessment Register (APAR) can subcontract if their delivery exceeds £100,000 annually.
3Reflects the current academic year and latest guidance.
3Strengthened detail on the flexible learning model
3Clarified Colchester Institute’s direct delivery role within the Operational Firefighter Level 3 Apprenticeship
3Included reference to Funding Higher Risk Organisations and Subcontractors Policy
3Added requirements for subcontractors below £100,000, including possession of a current UKPRN
3Strengthened evidence requirements for subcontractors to demonstrate high quality standards
Version NumberPolicy Year: 2026/27

 

4Updated policy references to Apprenticeship Funding Rules 2026/27 and Subcontracting Funding Rules 2026/27

Throughout

 

4

Updated policy references to reflect current DWP/DfE apprenticeship funding arrangements
4Added Subcontracting Reduction Strategy 2026/27

 

 

4

Added requirement to undertake and retain documented value for money and market analysis assessments as part of subcontractor selection, renewal and due diligence processes
 

4

Added clarification that subcontractors are prohibited from further subcontracting funded provision and must obtain prior written approval for any third-party delivery arrangements
 

4

Updated Localisation section to reference the Greater Essex LSIP, originally published August 2023, and the June 2025 Progress Report
4Removed ABA Procurement as a current subcontractor as the College now delivers inhouse.
4Updated subcontracting rationale to align with Skills England priorities and Growth & Skills Levy reforms
4Updated external audit and subcontracting assurance references following successful 2026 review
4Updated contingency arrangements and policy references from 2025/26 to 2026/27
4.1For in-year changes
[/su_table]
Yes/NoComments
1Does the policy/guidance affect one group less or more favourably than another on the basis of:
Race or ethnicityNo
DisabilityNo
GenderNo
Religion or beliefNo
Sexual orientationNo
AgeNo
Marriage and Civil PartnershipNo
Maternity and PregnancyNo
Gender ReassignmentNo
2Is there any evidence that some groups are affected differently?No
3If you have identified potential discrimination, are any exceptions valid, legal and/or justifiable?N/A
4Is the impact of the policy/guidance likely to be negative?No
5If so, can the impact be avoided?N/A
6What alternatives are there to achieving the policy/guidance without the impact?N/A
7Can we reduce the impact by taking different action?N/A

Table of Contents

Toggle
  • Subcontracting Policy – 2026/27
    • Apprenticeships and Adult Skills Funding
    • Overview of Policy
    • Subcontracting Strategy
      • Priority 1: An Outstanding Learner Experience
      • Priority 2: A Fantastic Workplace
      • Priority 3: Financial Strength and Physical Resources
      • Priority 4: A Responsive Curriculum
      • Priority 5: Productive Partnerships
      • Overall Rationale for Subcontracting
    • Subcontractor Policy
    • Fees and Payments
    • College Support for Subcontractors
    • Teaching, Learning & Assessment (T, L, & A)
    • Policy Review and Communication
    • Duties within Colchester Institute
    • Publication of Policy
    • Subcontracting Contingency Plan 2026/27
    • Appendix 1

Overview of Policy

This policy, which is renewed annually, details Colchester Institute’s Subcontractor strategy and management.

Subcontracting Strategy

The College Strategic Plan 2024-2028 details five key strategic priorities:

Priority 1: An Outstanding Learner Experience

Colchester Institute is committed to delivering high-quality teaching and learning, personalised support, and exceptional progression outcomes. The goal is to ensure learners are equipped with the skills, knowledge and behaviours to succeed in work and life.

How subcontracting supports this:

Subcontractors enable the College to offer specialist provision and flexible delivery models that enhance learner access, experience, and achievement, particularly in niche or employer-specific areas.

Priority 2: A Fantastic Workplace

This priority focuses on creating an inclusive, empowered, and collaborative culture where staff are supported, trusted, and developed, making Colchester Institute a great place to work.

How subcontracting supports this:

Strategic partnerships reduce the pressure on direct delivery teams in high-demand sectors and allow internal staff to focus on continuous improvement and innovation, rather than covering broad programme scopes alone.

Priority 3: Financial Strength and Physical Resources

The College aims to ensure long-term financial sustainability, invest in modern facilities, and maximise the use of its estate and digital resources.

How subcontracting supports this:

Subcontracting allows the College to expand provision without incurring the upfront costs of specialist infrastructure or full-time staffing in low-volume or geographically dispersed areas.

Priority 4: A Responsive Curriculum

Colchester Institute’s curriculum is shaped by employer need, labour market intelligence, and strategic priorities such as green skills, digital skills and health and care. It is regularly reviewed to remain relevant and future-facing.

How subcontracting supports this:

Subcontracting enables rapid responsiveness to emerging skills gaps, allowing the College to partner with providers who can deliver bespoke or innovative training at pace in line with the Local Skills Improvement Plan (LSIP).

Priority 5: Productive Partnerships

The College is committed to strong collaborations with employers, local authorities, training providers, and civic organisations to maximise community and economic impact.

How subcontracting supports this:

Engaging with subcontractors helps the College extend its reach, strengthen employer-facing solutions, and co-deliver training through trusted partnerships that reflect local and national skills strategies.

Overall Rationale for Subcontracting

Colchester Institute subcontracts to extend its capacity, meet employer demand, offer specialist or geographically targeted provision, and respond flexibly to the priorities of government, local skills plans, and learners. Subcontracting is not used to outsource core delivery but to add value, reach new learners, and meet unmet demand in ways that are high-quality, cost-effective, and aligned with the College’s strategic plan.

In line with the College’s Strategic goals, the College will consider a subcontractor arrangement where another organisation can provide:

  • Training linked to specific employer demand – primarily throughout the Essex, Suffolk and Norfolk regions.
  • A niche service, emerging market or expertise working with a specific learner group.
  • The ability to support larger volumes of learners than the College can reach in skills shortage areas, such as Health and Care to meet increased demand.
  • Specialist resources or expertise, not available at the college
  • Opportunities to expand the College’s offer into new markets.
  • A flexible learning model for those who are unable or unwilling to attend College campuses.
  • Improved geographical access for learners, particularly in hard-to-reach or rural areas.
  • Enhanced access routes for disadvantaged groups, supporting greater participation in learning.
  • Targeted support for individuals who share protected characteristics, where there may otherwise be gaps in provision or progression opportunities

To determine suitability for a subcontractor arrangement, due diligence processes will be carried out by the College. Colchester Institute will comply with all current subcontracting thresholds and registration requirements specified within the Apprenticeship Funding Rules and Subcontracting Funding Rules. These processes include a pre-contract questionnaire to ensure that the organisation can demonstrate its suitability to act as a subcontractor, followed by an in-person pre-contract compliance audit focused on quality assurance. Once an organisation has been approved, an annual compliance audit will be carried out, along with regular review meetings.

Value for Money and Market Analysis

Prior to entering, renewing or extending any subcontracting arrangement, Colchester Institute will undertake and document an assessment of value for money and market conditions. This assessment will consider factors including quality of provision, specialist expertise, geographical reach, employer demand, learner outcomes, capacity, risk, and cost effectiveness.

The outcomes of the value for money and market analysis process will be retained within the tendering and due diligence records to demonstrate that appropriate consideration has been given to achieving value for money, supporting learner success and ensuring the effective use of public funds.

Rationale for Current Subcontracting Arrangements (2026/27)

Colchester Institute engages in subcontracting arrangements only where they add value, extend capacity, or provide specialist expertise that cannot be delivered internally to the same standard or reach. Each partnership is strategically aligned to curriculum need, employer demand, or national skills priorities, with quality assurance retained in-house. The rationale for each current subcontractor is outlined below:

Essex Fire and Rescue Service – Operational Firefighter Level 3 Apprenticeship

Colchester Institute subcontracts with Essex County Fire and Rescue Service to deliver the Operational Firefighter Level 3 Apprenticeship, which serves as the sole entry route into the profession for new, inexperienced firefighters. Delivery must take place within an operational fire service environment by occupationally competent staff.

Colchester Institute retains direct responsibility for key elements of the on-programme delivery, including progress reviews, off-the-job training monitoring, and on-programme assessment support. This includes preparing apprentices for assessment through guidance, feedback, and skills development aligned to the standard.

This subcontracting arrangement ensures that, while specialist practical training is delivered by the Fire and Rescue Service, the College maintains overall responsibility for quality assurance, compliance with sector-specific training standards, and robust oversight of apprentice progress and outcomes.

Blue Sky – HR Apprenticeships (CIPD Levels 3, 5 & 7)

Colchester Institute subcontracts with Blue Sky, a CIPD-approved centre, to deliver the knowledge components of the HR Support Level 3 (Norfolk only), HR Consultant/Partner Level 5, and Senior People Professional Level 7 apprenticeships. This enables the College to offer CIPD-aligned HR qualifications across Essex, Suffolk, and Norfolk, ensuring high-quality delivery while retaining responsibility for employer liaison, quality assurance, and full programme oversight.

Learning Curve Group – Adult Skills Fund (ASF) Provision

Colchester Institute subcontracts with Learning Curve Group (LCG) to deliver Adult Skills Fund provision, primarily funded through the National Skills Fund (NSF). This partnership focuses on online and flexible learning programmes, targeting learners within a 30-mile radius of Colchester Institute to maintain a localised skills impact. LCG offers specialist Level 3 provision and digital delivery infrastructure that supports national skills priorities and increases accessibility for adult learners who may be unable to attend in-person provision.

Cambridge Fire and Rescue Service – Operational Firefighter Level 3 Apprenticeship

Colchester Institute subcontracts with Cambridge Fire and Rescue Service to deliver the Operational Firefighter Level 3 Apprenticeship, which serves as one of the entry routes into the profession for new, inexperienced firefighters. The initial 10-week basic skills training is delivered within an operational fire service environment by occupationally competent staff to ensure authenticity and sector relevance.

Colchester Institute retains direct responsibility for key elements of the on-programme delivery, including progress reviews, off-the-job training monitoring, and on-programme assessment support. This includes preparing apprentices for assessment through guidance, feedback, and skills development aligned to the standard.

This subcontracting arrangement ensures that, while specialist practical training is delivered by the Fire and Rescue Service, the College maintains overall responsibility for quality assurance, compliance with sector-specific training standards, and robust oversight of apprentice progress and outcomes.

Subcontracting Reduction Strategy 2026/27

Colchester Institute is committed to reducing reliance on subcontracted delivery where direct delivery can be achieved without adversely impacting quality, employer responsiveness or learner outcomes.

During 2025/26 the College:

  • Transitioned Procurement Apprenticeships to direct delivery following approval as a CIPS Centre.
  • Continued direct delivery of CIPD Level 3 HR apprenticeships.
  • Established plans to move CIPD Level 5 HR apprenticeships to direct delivery from September 2027.
  • Continues to review all subcontracting arrangements annually.

The College will retain subcontracting arrangements only where there is a clear educational, geographical or specialist occupational rationale.

Localisation

The College is actively engaged in responding to the priorities identified within the Greater Essex Local Skills Improvement Plan (LSIP), originally published in August 2023 and most recently reviewed through the Greater Essex LSIP Progress Report published in June 2025.

Colchester Institute works closely with employers, sector bodies and regional stakeholders to ensure that subcontracted provision aligns with local labour market demand, employer skills priorities and emerging workforce needs across Essex, Southend, Thurrock, Suffolk and Norfolk.

The College will continue to review its curriculum and subcontracting arrangements against future LSIP developments, Skills England priorities and national skills policy to ensure provision remains responsive to employer demand and supports economic growth within the region.

Further information can be found via the Essex Chambers of Commerce LSIP website.

Subcontractor Policy

This policy applies to all subcontracted provision supported with funds supplied by Department for Work and Pensions (DWP) apprenticeship funding rules and associated Department for Education (DfE) guidance. The policy has been developed in accordance with the Apprenticeship Funding Rules 2026/27, Adult Skills Fund Funding Rules 2026/27, the Subcontracting Funding Rules for Post-16 Education and Training 2026/27 and associated government guidance.

Colchester Institute retains full accountability for all subcontracted provision, including quality, compliance, safeguarding, learner outcomes, funding assurance and whole-programme oversight. The College has robust partnership management processes in place to ensure subcontracting arrangements meet funding, quality and compliance requirements. As part of the DfE Subcontracting Standard, subcontracting arrangements are subject to annual due diligence, contract management reviews, quality assurance activities and risk assessment.

External Audit Arrangements

Colchester Institute successfully completed its external Subcontracting Standard Assurance Review in June 2026 and will continue to undertake annual internal reviews and future external reviews in accordance with DfE requirements.

Apprenticeship Delivery Arrangements

Colchester Institute will ensure that all apprenticeship delivery arrangements comply with current apprenticeship funding rules and subcontracting requirements.

From 1 January 2027, the College will review all apprenticeship delivery arrangements involving self-employed workers, freelancers, sole traders and individuals engaged through contracts for services to ensure compliance with the revised subcontractor definitions and associated government guidance.

Any arrangement that meets the definition of subcontracting under the funding rules will be subject to the College’s subcontracting due diligence, approval, contracting and quality assurance processes.

Colchester Institute works with a small number of subcontractors to deliver high-quality education and training where there is a clear educational, geographical, specialist or employer-led rationale. All subcontracting arrangements must support employer demand, local skills priorities and the College Strategic Plan.

The following principles apply to all subcontracting arrangements:

  1. All subcontractors delivering apprenticeship provision above the funding threshold specified within current funding rules must be registered on the Apprenticeship Provider and Assessment Register (APAR) and hold a current UKPRN.
  2. Subcontractors must not further subcontract any element of provision funded through Colchester Institute. Any delivery arrangements involving third parties, self-employed workers, freelancers or sole traders that may meet the definition of subcontracting must be disclosed to and approved in writing by Colchester Institute prior to delivery commencing
  3. All subcontractors will be expected to complete an annual tender and due diligence process prior to a contract being awarded.
  4. All subcontractors will be subject to financial health checks, quality assurance reviews and compliance monitoring in accordance with funding rules and College procedures.
  5. Consideration of subcontractors identified as higher risk will be undertaken in accordance with current government funding rules and guidance.
  6. A Contract Management Plan will be maintained for each subcontracting arrangement.
  7. All subcontractors must maintain a complete audit trail demonstrating compliance with funding rules and subcontracting requirements.
  8. All subcontractors must provide evidence of financial viability and maintain appropriate safeguarding, health and safety, data protection and business continuity arrangements.

 

Learner Eligibility

Colchester Institute will maintain sufficient evidence to demonstrate learner eligibility, residency, employment status, right to work and any other eligibility criteria required by funding rules.”.

The list of Subcontractors for 2026-27 are shown below:

Sub-contractorFunding Type and Contract ValueDelivering
Learning Curve Group LtdTBC for 2026/27A range of Level 3 programmes delivered to eligible adults
Blue Sky Professional DevelopmentApprenticeships – New Starts and carry-in 2026-27CIPD mandatory qualification at levels 3 (Norwich only), 5 and level 7
Essex County Fire and RescueApprenticeships – New Starts and carry-in funding 2026-27Delivery of 15 week basic skills training
Cambridge Fire and RescueApprenticeships –

New Starts 2026-27

Delivery of 10 week basic skills training

Fees and Payments

For the provision of apprenticeships, Colchester Institute agrees to pay the subcontractor an agreed fee per apprentice. This charge is recorded in the contract and is set for the duration of the contract. Charges are reviewed annually and updated in line with any changes to the apprenticeship standard. Where the subcontractor requires services which exceed those outlined in the current agreement from Colchester Institute, an increased charge will be negotiated.

Colchester Institute retains an agreed management fee, which is negotiated with the subcontractor at the start of the contract. Payment is made for delivery of agreed services

Subcontracted adult funding is capped at 20% of the maximum contract value and 80% of the subcontracted funding is passed to the subcontractor for the delivery of ASF funded courses. The 20% fee retained by Colchester Institute covers the provision of:

  • administration
  • quality assurance and compliance
  • MIS function relating to the submission of funding claims to the DfE
  • provision of management meetings
  • provision of a dedicated account manager

Colchester Institutes overall aim is that learners engaged with the subcontractor achieve the maximum benefit from the provision. The subcontractor will be responsible for meeting the costs associated with the registration of candidates with awarding bodies and examination fees. Non-standard charges may be applied to other subcontracting agreements in the future where costs can be mutually identified and agreed between the subcontractor and Colchester Institute.

The College will review subcontracting arrangements annually to ensure they remain aligned with national apprenticeship funding reforms, Growth and Skills Levy developments and Skills England priorities.

Payment Arrangements

Payments will be made monthly or as agreed with the subcontractor and will be reviewed quarterly.

  • Following the validation of evidence in the ILR return the College will make the appropriate payment to the subcontractor and any adjustments for reconciliation.
  • Specific payment profiles will be attached to each contract.
  • Where non-delivery has been identified, clawback of funds will be reconciled the following month, unless occurring at the end of the contract year, where an invoice will be raised, and repayment requested.

College Support for Subcontractors

The exact mix and level of support for each subcontractor will be assessed initially as part of the due diligence process, prior to contracting, and thereafter on an annual basis. A contract renewal meeting will be held with any subcontracting organisation who is continuing an ongoing partnership.

For new subcontractors, monthly reviews will be conducted by the Director of Apprenticeships and the subcontractor to identify any day-to-day operation and administrative issues. All subcontractors will be subject to regular review.

In addition to working within the College’s own quality assurance processes, subcontractors will be subject to additional quality checks and support from the College’s Quality and Innovation Team. Other areas of College support include input and guidance on the following:

  • Support with due diligence.
  • Establishing and maintaining quality management systems.
  • Certification and registration with awarding bodies.
  • Audit of management systems.
  • Support & audit of learner paperwork.
  • Curriculum, Observation of Teaching and Learning and Quality support.
  • A training and development offer – including training related to organisational performance improvement.

Teaching, Learning & Assessment (T, L, & A)

The College is committed to improving the quality of teaching and learning within our supply chain and along with the partnership quarterly review meetings, the additional quality checks and training opportunities listed below are included within our fees and subcontractor charges:

  • Initial Quality and Curriculum Visit: before a contract is given, a quality and curriculum representative will visit a partner provider and complete the initial quality assessment report.
  • Partner Training Events on developing and embedding good consistent practice in T, L & A, safeguarding, reviewing apprentice progress, PREVENT and other mandatory learning and development as identified through the College’s quality assurance processes.
  • Any actions will be highlighted in the quarterly partner review meetings. If the partner is classed as high risk, a member of the quality team will also attend until the risk is reduced.
  • Annual unannounced visit: a quality/curriculum representative will undertake an unannounced visit.
  • Self-Assessment: support with the completion of the annual SAR cycle.
  • Review of tracking and predicted achievement rates.

The College is committed to maintaining high quality teaching and learning, and the proportion of the fees retained by the College are reasonable and reflect the College’s own costs to deliver the services provided.

Policy Review and Communication

Colchester Institute will review this policy annually. Any changes to the policy will be communicated to existing subcontractors at the contract management meetings. The policy will be discussed with new subcontractors prior to their engagement. An up-to- date copy of this policy will be posted on Colchester Institutes website and paper copies will be made available upon request.

Duties within Colchester Institute

Nominated members of staff with strategic lead responsibility for subcontracting:

  • Deputy Principal
  • Director of Apprenticeships and Business Solutions

Nominated member of staff with responsibility for performance management of subcontractors:

  • Quality Enhancement Officer

Publication of Policy

This policy is published on the College’s Website and issued to all partner organisations.

Subcontracting Contingency Plan 2026/27

If a subcontractor fails to deliver against the contract or the contract is terminated, the College will take steps to ensure that provision is made to preserve the continuity of the provision and learners involved are able to complete their qualifications. The contingency process that will be followed is documented in Appendix 1.

Appendix 1

Subcontractor Contingency Plan

To be implemented when a subcontractor is no longer trading, fails to deliver against the contract or the contract is terminated.

Stage 1:

  • Contact all learners, employers, and any other relevant stakeholders to make them aware of the situation and advise them that the College will be making alternative arrangements.
  • Conduct an assessment of learners’ current progress.
  • Secure all evidence such as reviews, registers, and portfolios.
  • Notify the DfE if appropriate.

Stage 2:

  • Complete the Contingency Plan (see attached)
  • Create a bespoke action plan for each learner.
  • Put in place appropriate alternative arrangements. For example, relevant College staff where the College is directly taking over provision or seek alternative providers if the College is unable to take over the provision directly.
  • Secure appropriate awarding body approval where required.
  • Liaise with all stakeholders including employers to minimise the impact on learners and to support the learners continued development (more intensive if needed).

Contingency Plan

This plan should be completed by the appropriate representative of the College in the event of any of the circumstances listed below:

  • The College has taken the decision to withdraw from a subcontract arrangement and learners are still on programme.
  • A Subcontractor has withdrawn from the arrangement and learners are still on programme.
  • A Subcontractor goes into liquidation or administration and learners are still on programme.
Partner Name
Date of Plan
College Representative and title
Partner Representative and title
Summary of circumstances leading to the current position and completion of plan
ActionsTimescales and Target DatesResponsible PersonResourcesProgress UpdateReview Date
Stakeholder engagement /notifications to relevant funding body*
Recipient Partner engagement
Communications Plan
Learner / Participant Transition Plan, including safeguarding and health and safety
Learner / Participant Files (including e- portfolio), Data Management and Finance

*For DfE – confirm that the declaration of subcontractors has been updated by the relevant College representative. I/we agree this information is accurate and agree to complete the actions noted on this document.

Signed………………………………………………………………………………………………………………………… on behalf of Subcontractor                                                                                                       Date:

Signed………………………………………………………………………………………………………………………… on behalf of the College                                                                                                       Date:

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Colchester Institute Responds to Government Withdrawal of Management and Leadership Apprenticeship Funding

“The Government’s decision to defund management and leadership apprenticeship standards from September 2026 represents a significant change for employers and providers across the sector. At Colchester Institute, our commitment remains to support employers and apprentices through a smooth transition, ensuring continuity for existing learners while shaping new, high‑quality pathways for future leadership development. We will work in partnership with our employers to co‑design practical alternatives that continue to strengthen workforce capability and build organisational resilience.” – Ashley Gallagher, Head of Professional Apprenticeships and Skills at Colchester Institute

The Department for Education (DfE) has confirmed that funding for certain management and leadership apprenticeship standards will be withdrawn from 1 September 2026.

The affected standards currently delivered by Colchester Institute include:

  • Team Leader/Supervisor (Level 3)
  • Operations/Departmental Manager (Level 5)
  • Coaching Professional (Level 5)
  • Chartered Manager Degree Apprenticeship (Level 6)

In addition, the DfE has announced a national cap is being placed on new apprenticeship starts, limiting the number of new enrolments permitted across the sector between now and August 2026.

Please note, existing apprentices are unaffected and will continue their studies as planned.

We recognise how important these programmes are for developing leadership and management capability within organisations. We remain committed to:

  • Safeguarding the progress of existing apprentices.
  • Managing remaining start opportunities responsibly and in line with national guidance.
  • Working collaboratively with employers to design a new, high‑quality alternative curriculum offer that supports continuing leadership and skills development beyond 2026.

A consultation process with employers will launch shortly. This will inform our future leadership and management training provision, including both apprenticeship and non‑apprenticeship options. We welcome input from a range of stakeholders, and should you wish to contribute to shaping the future of our management offer, please reach out to employers@colchester.ac.uk help shape the conversation.

Further national and local updates will be provided here as soon as new guidance becomes available.