The U.S. Department of Labor’s Employment and Training Administration (ETA) released updated Office of Apprenticeship (OA) Circulars and a Bulletin that introduce significant changes to Registered Apprenticeship (RA) program design, performance evaluation, and registration processes.
These updates reflect a shift toward increased program flexibility paired with stronger expectations for documentation, standardization, and measurable outcomes.
View Updated USDOL ETA Registered Apprenticeship Guidance Documents
Circular 2026-01: Registered Apprenticeship Training Approaches
This circular replaces prior 2016-era guidance and clarifies allowable program structures under 29 CFR Part 29.
Key Takeaways:
- Expanded program design flexibility: Sponsors may implement competency-based, time-based, or hybrid models without previously enforced sub-regulatory limits (e.g., minimum duration or caps on prior learning credit).
- Elimination of informal constraints: Prior limitations—such as a 12-month minimum for competency-based programs or a 50% cap on prior experience credit—have been rescinded at the federal level (though state-level enforcement may still apply).
- Increased emphasis on written standards: Sponsors must clearly define on-the-job learning (OJL), competencies, work processes, and evaluation methods in program standards.
- Advanced standing requirements: Credit for prior experience or demonstrated competency must be supported by objective, uniformly applied policies aligned with 29 CFR 29.5(b)(12).
- Related instruction flexibility: The 144-hour annual recommendation remains, but delivery methods may vary (e.g., online, front-loaded, or hybrid), provided instructor qualifications and quality standards are met.
- Documentation and completion integrity: Sponsors must maintain defensible documentation verifying that apprentices meet all approved standards prior to completion.
Circular 2026-03: Apprenticeship Completion Rates
This circular formalizes completion rates as a standardized, cohort-based performance metric and introduces public benchmarking.
Key Takeaways:
- Standardized cohort methodology: Completion rates are calculated using a defined cohort (registered apprentices within a fiscal year, excluding probationary cancellations).
- Formal performance indicator: Completion rates will be used by Registration Agencies to assess program quality and compare performance against national benchmarks.
- Public transparency: ETA will release completion and cancellation rate data by industry, state, and nationally via a public data portal.
- One-year lag in reporting: Apprentices are given an additional year beyond their expected completion date (ECD) to finish, delaying public reporting.
- Performance management approach: Low completion rates trigger technical assistance and continuous improvement efforts before any consideration of deregistration.
- Operational implications for intermediaries: Requires robust tracking of cohorts, retention, probationary exits, and employer-level performance.
Bulletin 2026-35: 30-Day Registration Determination Timeline
This bulletin establishes a defined federal processing timeline for apprenticeship program registration decisions.
Key Takeaways:
- 30-day determination commitment: OA will issue a registration decision within 30 days after receipt of final, signed standards.
- Applies to final submission phase only: The timeline begins after program design is complete and documentation is formally submitted—not during development.
- Standards Builder utilization encouraged: Use of the federal Standards Builder platform supports transparency and tracking of approval timelines.
- Regulatory compliance unchanged: All requirements under 29 CFR Part 29 remain fully in effect—no reduction in quality or compliance standards.
- Transparency via “shot clock”: A public-facing dashboard will track registration volume and average processing time.
- Reset conditions: If standards are revised and resubmitted, a new 30-day review period begins.
Circular 2026-02: Roles of State Apprenticeship Agencies (SAAs) and Councils (SACs)
While not directly applicable to Michigan’s current structure, this circular provides important clarification on governance roles within the apprenticeship system.
Key Takeaways:
- SAA authority reaffirmed: State Apprenticeship Agencies are the sole entities responsible for program approval, oversight, and deregistration decisions.
- SAC role limited to advisory: State Apprenticeship Councils may provide input but cannot function as decision-making bodies.
- Reduction of administrative barriers: The guidance addresses delays caused by SAC-controlled approval processes and reinforces timely decision-making expectations.
- Federal backstop authority: OA retains the ability to register programs in SAA states if state-level processes impede system effectiveness.
System-Level Implications for Intermediaries and Group Sponsors
Collectively, these updates signal a shift toward a more data-driven, transparent, and standardized apprenticeship system.
Key Takeaways:
- Flexibility with accountability: Greater latitude in program design must be matched with rigorous documentation and compliance.
- Performance visibility: Completion rates will serve as a primary indicator of program quality and sustainability.
- Operational readiness: Intermediaries must strengthen data tracking, employer engagement strategies, and retention supports.
- Process efficiency: Defined federal timelines create opportunities to streamline program launch—if standards are submission-ready.
- Governance clarity: Clear delineation of state roles supports more consistent and timely program approval processes.
What This Means for Michigan and WIN Partners
Together, these updates reflect a broader shift in the national apprenticeship system:
- More flexibility in program design
- Greater transparency and public performance data
- Stronger emphasis on outcomes and completion
- Improved timelines for program approval
For WIN and our partners, this is an opportunity to strengthen program quality, enhance employer engagement, and ensure apprentices are supported from enrollment through completion.
View All USDOL ETA Registered Apprenticeship Guidance Documents
Materials created with AI and reviewed by WIN Staff. 
By Jessica Keenan, WIN Workforce Project Manager
About the Workforce Intelligence Network (WIN)
The Workforce Intelligence Network for Southeast Michigan (WIN) is a collaborative partnership of nine community colleges and seven Michigan Works! Agencies. WIN’s mission is to help cultivate a cohesive talent system by facilitating data-driven workforce solutions that respond to the region’s changing labor market demands. Its work is guided by three core pillars: Research, Engagement, and Solutions, driving collaboration and connecting education with industry.
Through initiatives like the Advance Michigan Center for Apprenticeship Innovation (AMCAI), WIN helps employers and educators expand access to Registered Apprenticeships and build a sustainable, skilled workforce for Southeast Michigan. For more information, visit winintelligence.org and miapprenticeship.org.
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