ADVISORY: OFFICE OF APPRENTICESHIP CIRCULAR NO. 2026-01 SUBJECT: Registered Apprenticeship Training Approaches Key takeaway:
This 2026 OA Circular replaces the old 2016 guidance and gives sponsors more flexibility, while putting more weight on having clear written standards, consistent policies, documentation, and Registration Agency approval.
What Matters Most for an Intermediary / Group Sponsor: •
You can structure programs competency-based, hybrid, or time-based, but your standards must clearly spell out how OJL, competencies, work processes, and evaluation will work.
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Federal OA rescinded several old limits that were not actually in regulation, but the MI Office of Apprenticeship may still enforce this rule. o
no fixed 12-month minimum for competency-based programs
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no strict 25% limit on time-based or hybrid term adjustments
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no 50% cap on previous-learning or previous experience credit, and
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no 6-month/1,000-hour minimum for issuing a completion certificate.
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For advanced standing, sponsors need an objective, uniformly applied written policy adhering to 29 CFR 29.5(b)(12), matching wage progression, and documentation to back every credit decision. Advanced standing may be granted based on an apprentice’s prior experience, an apprentice’s demonstrated competency during on-the-job learning, or both.
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Related instruction is still required in all models. The 144-hours-per-year is recommended, not mandatory, and delivery can be front-loaded, segmented, concurrent, online, self-study, etc., if appropriate and approved. All apprenticeship instructors must have training in teaching techniques and adult learning styles.
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Completion decisions hinge on whether the apprentice met the approved standards, and the sponsor must certify and document that completion.
Bottom Line:
This Circular gives more design flexibility, but it also raises the bar on policy discipline, documentation, consistency across employer partners, and defensible standards review.