Sub Contract Policy

Subcontract management and retained funding policy


SBC Training Ltd operates as a main provider on the Register of Apprenticeship Training Provider list (RoATP). Some provision is delivered via sub-contractor organisations to enable the provision of a wider choice of appropriate Apprenticeship Standards to employers and learners within the guidelines of current ESFA funding/subcontracting rules. All providers undergo appropriate due diligence processes prior to undertaking any delivery.


The board of directors (governance) supports the granting of subcontract agreements that meet all/any of the following criteria:

  • Accessibility (geographic location and subject area)

  • Meets the needs of employer organisations who have an existing relationship with SBC Training

  • Potentially widens participation for disadvantaged groups

  • Fills gaps in specialist provision and enhances learner opportunities

  • Enhances the quality of teaching and learning available within the locality

The following policy applies to all provision that is sub-contracted and is effective from 1st August 2023.

Identification of need

The Operational Management (OM) group at SBC Training will identify the need for subcontracting at the commencement of/during the current financial year. The OM will inform the board of directors. The OM will source suitable subcontractors from either of the following:

  • Existing subcontractors

  • Subcontractors who have requested a sub-contract

  • Publishing an open tender

Due Diligence

An appropriate due diligence process will be carried out prior to the provision of a subcontract. The process will include (but is not restricted to) the following actions:

  • Meeting between OM team and prospective subcontractor

  • Examination of financial reports

  • Companies House check

  • UKRLP check

  • Completion of due diligence questionnaire

  • Assessment of delivery capabilities

  • Resource/facilities investigation

Completion of the due diligence process may lead to the offer of a sub-contract.

Retained Funding

SBC Training provides a benchmark minimum retention rate of 10%; with any direct costs of providing access to funding agreed in consultation with individual organisations with the prime aim of ensuring that the value to the learner and their employer is maximised. Any additional risks identified may lead to increased funding retention to compensate for agreed additional support that may be provided through agreement with the subcontractor. The agreed fee(s) is applied to Education Skills Funding Agency (ESFA) funded programmes and will be deducted prior to payments being made to providers. All payments will be made against ESFA monthly funding reports, subject to providers meeting the requirements outlined in the individual sub-contract agreement and current ESFA funding rules applicable at the time of the claim. Payments will normally be made on or before the last working day of the month following entry onto the Individualised Learner Record (ILR).

Additional Charges

SBC Training will consider levying additional fees should management of the sub-contractor require additional administrative and or quality guidance/support to effectively manage their contract.

Additional Support

SBC Training has a responsibility to support all sub-contract partners to develop and deliver high quality training that meets (and where possible exceeds) the needs of learners and employers. Retained funding is used to meet the direct cost of provision of a range of support and compliance measures to ensure that public funds are protected and used effectively.

The exact support will vary dependent upon the sub-contractor needs, but may include:

  • Functional Skills support training

  • Quality consultant support

  • Safeguarding consultancy and training

  • Staff development resulting from Observation of Teaching & Learning (OTL)

  • Access to Functional Skills resources

  • Access to e-portfolio resources

  • Management Information (MIS) services

  • Self-assessment and quality assurance support/guidance


Successful applicants will be provided with a contract manager who will agree a schedule of reviews to cover all aspects of the agreed delivery programme. Monitoring of the programme could include both planned and unplanned observations of delivery throughout the life of the sub-contract agreement.

Monitoring would normally include the following processes:

  • Learner progress/ file checks

  • Internal and external quality processes

  • Learner eligibility and data checks

  • Review of organisational policies/procedures

  • Learner interviews


Audits will be undertaken with the subcontractor. Audit schedules will be agreed in advance and will sample records based upon an agreed risk rating; Low >20% of learner records; Medium >20%60 – 100% of learner records.

Feedback with agreed action plans will be provided to the subcontractor with actions to be completed within 1 month following receipt of the report.

Unsatisfactory compliance and/or quality

Failure to meet expected standards of performance may result in further action plans being put in place with failure to address outstanding concerns leading to possible termination of sub-contract agreements.

General Data Protection Regulations (GDPR)

SBC Training and its subcontractors acknowledge that they will work in accordance with the GDPR and the Data Protection Act 2018.

SBC Training is a data controller and produces policy documents that acknowledge its data management responsibilities. These are available on the SBC Training website

Policy Review

This policy is due for review in July 2024 and will be published at