2026 March ETA Circulars and Bulletins Overview

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.

• Federal OA rescinded several old limits that were not actually in regulation, but the MI Office of Apprenticeship may still enforce this rule.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

o no strict 25% limit on time-based or hybrid term adjustments

o no 50% cap on previous-learning or previous experience credit, and

o no 6-month/1,000-hour minimum for issuing a completion certificate.

• 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.

• 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.

• 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.

ADVISORY: OFFICE OF APPRENTICESHIP CIRCULAR NO.

2026-03

SUBJECT: Registered Apprenticeship Program Completion Rates

Key Takeaway:

The Office of Apprenticeship is standardizing how Registered Apprenticeship Program completion rates are calculated and reported and making them a clearer part of how program performance is evaluated. The guidance also increases transparency by adding public completion and cancellation rate data.

What Matters Most for an Intermediary / Group Sponsor:

• Completion rates are now a more formal performance signal. Registration Agencies will use them when evaluating RAP performance, comparing programs to the national average.

• The calculation is cohort-based and standardized.

o A cohort is apprentices registered in a program during a fiscal year, excluding those canceled during probation.

o The completion rate formula is: x / (y-z)

 x = total number of apprentices in the cohort who completed their program requirements on or before one full year after the program’s ECD.

 y = total number of registered apprentices in the cohort with an ECD for a set period of time (e.g., FY 2024) plus one full year.

 z = total number of apprentices in the cohort who exited the program, for whatever reason, during the probationary period.

• Low completion rates trigger technical assistance first. The point is improvement, not immediate penalty. Deregistration is only contemplated when there is an ongoing pattern of very low completion rates over several years.

• There will be public benchmarking data. OA is releasing a data portal with average completion rates nationally, by state, and by industry, along with cancellation rates.

• There is a built-in one-year lag. Completion and cancellation rates for a given fiscal year are not released until the following year, because apprentices are given an extra year beyond their expected completion date to finish.

Bottom Line:

Group sponsors and intermediaries should closely track cohorts, expected completion dates, probationary exits, and post-probation retention across participating employers. This guidance makes completion rates a more visible quality metric, so intermediaries should use the new benchmarking data to identify weak spots early, target retention supports, and help employers improve long-term completion outcomes.

OFFICE OF APPRENTICESHIP BULLETIN:

2026-35

SUBJECT: Announcement of Office of Apprenticeship 30-day Commitment to Apprenticeship Program Registration Determinations and new virtual “Shot Clock” website

Key Takeaway:

For OA-state Registered Apprenticeship programs, the Office of Apprenticeship says it will make a registration determination within 30 days after a sponsor submits final signed standards. This applies to local standards submitted through Standards Builder and to National Program Standards and National Guideline Standards submitted to OA staff.

OA is also launching a public “shot clock” website to show monthly registration volume and average processing time

What Matters Most for an Intermediary / Group Sponsor:

• The 30-day clock starts only after program development is complete and the final signed standards are submitted for OA review and approval. It does not cover the earlier consultative design phase.

• Using Standards Builder matters because OA says it helps create transparency in approval times and allows the agency to track the registration process.

• This is most useful as a final-stage timeline commitment, not a promise that the full sponsor onboarding and program design process will take 30 days.

• 29 CFR Part 29 still fully applies, so quality and compliance requirements have not been relaxed.

• If OA cannot decide within 30 days, it must give the prospective sponsor written notice explaining the delay

• If standards are denied and then revised and resubmitted, a new 30-day clock begins.

• This bulletin does not apply to sponsors registering in SAA states, though SAAs are encouraged to streamline their own processes and adopt a similar approach.

Bottom Line:

For a group sponsor or intermediary, this creates a clearer timeline for the approval phase, so the biggest operational priority is making sure standards are truly final, signed, compliant, and submission-ready before sending them in.

Register for the Upcoming ETA Webinar: Key Sub-regulatory Guidance for the National Apprenticeship System

Circular 2026-02 Is Not Applicable to Apprenticeship in Michigan

ADVISORY: OFFICE OF APPRENTICESHIP CIRCULAR NO. 2026-02

SUBJECT: Roles and Functions of State Apprenticeship Agencies and State Apprenticeship Councils

Key takeaway:

For Registered Apprenticeship, the State Apprenticeship Agency must be the actual decisionmaker on registration and oversight. State Apprenticeship Councils can advise and support, but they should not control approval, denial, monitoring, suspension, or deregistration of programs.

What Matters Most for an Intermediary / Group Sponsor:

• If a SAC is acting like the gatekeeper for registration, that is the exact issue this bulletin is trying to correct.

• SAAs cannot hand off core functions to SACs, including deciding whether an occupation is apprenticeable, approving standards, approving or denying applications, monitoring programs, or suspending/deregistering programs.

• Delays caused by infrequent SAC meetings, postponed decisions, or lack of clear due process are called out as barriers that can slow sponsors trying to launch programs.

• If a sponsor faces those kinds of barriers, OA still has authority to register programs in SAA states when needed to further the interests of the National Apprenticeship System.

Bottom Line:

This bulletin gives sponsors and intermediaries a stronger basis to expect a more direct, timely, and legally aligned registration process through the SAA, with SACs serving in an advisory or limited-support role rather than functioning as the approval body.