September 2026 Provider Updates: FAM Changes and Subcontracting Review Delay
19 September 2026
Two items from the DfE's 9 September Further Education Update that providers may have missed — changes to the financial assurance monitoring guidance and a delay to the apprenticeship subcontracting rules review.
The DfE’s Further Education Update published on 9 September 2026 contained two items that are easy to miss but practically significant for apprenticeship providers.
Financial assurance monitoring guidance updated for 2026-27
The financial assurance monitoring (FAM) post-16 guidance for 2026 to 2027 is now live. Three changes from last year:
FRM37 removed. ‘Apprenticeship off-the-job training hours below the minimum’ has been removed from the monitoring framework. The reason given is that FRM37 only applied to apprentices who started before 1 August 2025. With all such learners now either completing or having left, there’s no longer a population to monitor against.
If you have been tracking OTJ compliance specifically to manage your FRM37 risk, this check will no longer appear in your dashboard. It’s not that the OTJ minimum no longer exists — it still does, and it still applies to all current apprentices — but this particular financial monitoring report is gone.
FRM01 updated. ‘Learners repeating a previously achieved learning aim’ has been updated to reduce duplication with another report. The substance is unchanged — learners who have already achieved an aim shouldn’t be re-funded for it — but the mechanics have been refined.
FRM27 repayment process changed. The process for repaying funding for ‘Continuing or completed learning aims that are now reported as withdrawn on or before 31 July of the previous funding year’ has been updated. Check the guidance for how repayments will now work if you have any learners in this category.
The first monitoring dashboard for 2026-27 will be available from December 2026, via View Your Education Data.
Subcontracting rules review delayed to August 2027
A full review of the subcontracting section of the apprenticeship funding rules has been underway since earlier this year. The review was originally expected to conclude by September 2026.
It won’t. The DfE now says:
- Engagement with sector representative bodies will begin towards the end of 2026
- Wider comment from the sector will follow in early 2027
- Any rule changes resulting from the review will take effect from August 2027
If you were expecting clarity on subcontracting requirements this autumn, it isn’t coming. Current rules remain in force through the 2026-27 year. Providers who use subcontracting arrangements should continue to apply the existing rules while the review runs.
The DfE says the later implementation date is intentional — to give providers “sufficient time to adjust to the changes” once they’re finalised.