Evidencing learning start date


Hi, i'm after some providers prior experience of ESFA audit around evidencing start of learning for remote/distance learning.

Previously, I've worked in colleges and classroom based learning environments so have never really paid much attention to the paragraph below from the ILR specification under the start date.

"In the case of open learning or distance learning, the date on which the first course material is sent or presented to the learner should be recorded."

My question is whether this accepted by ESFA auditors or do you also have to evidence that they have accessed these materials and completed some type of learning activity?



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Kelly Knights

Hi Paul,

If you refer to the start date section in this years ILR specification document you will find the below statement at the bottom: In the case of open learning or distance learning, the date on which the first course material is sent or presented to the learner should be recorded. In the case of accreditation of prior experience and learning, the start date would be the date on which the accreditation process started.

We use a platform licenced by Learning Curve called E-Assessor. From that we use the date that states "question bank allocated to learners" which means when they've set up the qualification on the learners portfolio - an auditor has okayed this as acceptable start of learning evidence. Actually during an audit last year the Auditor had forgotten or wasn't aware of the text in bold above and I did (quite smugly) point them in the direction of it.

if you don't use E-Assessor you'd need a form of a induction register stating that this is when they were given their leaning materials.

I hope this helps,


Melanie Aspinall

I've never really taken notice of that before but now I'm interested in this too!


Thanks. Yes we currently use a similar e-portfolio and the apprentices also undertake a thorough induction where learners are given access to the on-line learning materials. They also have to complete a reflection piece based on what they done. I say this as induction activity is listed in the funding guidance as ineligible costs so we steer well clear of saying induction is their start date.

I guess with my pessimistic hat on my question is were they happy to accept evidence the apprentice has been given access to the course material as 'learning'. It's there in black and white in the text but an auditor may take the stance that until the learner has accessed and started an activity within it, then learning hasn't happened.

Kelly Knights

Hi Paul My example was for an AEB learner rather than an apprentice. Im a little confused, is this apprenticeship delivery? If you're using an eportfolio system it will be down to the wording of the entry- backed up by a timetable/session evaluation

Debra Sinclair

Hi, this is a really interesting topic.  I would have thought, you can give course materials but how do you know the Apprentice has looked at them, and what learning has taken place?  So like you Paul,  I would be interested to clarify 'what evidences the learning from start'  In a Apprenticeship, would it be the day work is given.  The dates the learner declares they did the work, or the date it is evaluated and feedback given?

Jaci Littlewood

This question has come up time and time again within our company.  Please be careful when you use the term "Induction" as evidence of in learning.  We have been told by a few auditors that induction does not count as in learning and the Funding Rules state "The date learning begins. This does not include enrolment, induction, diagnostic assessment or prior assessment"

Kelly Knights

It defiantly should not be induction and you will need clear evidence to show what was covered. Anything related to the KSB is learning.


If you use a e-portfolio system then log it there.



Jaci Littlewood

I have a follow-up question. Would an auditor be happy that you could just produce evidence that you had "sent" or "presented" course material?  At a recent mock audit that we commissioned, although we recorded full details on the first leaner progress review (conducted on day 1 on the learning start date), that we supplied the apprentice with course work etc, and this was signed by the employer, learner and employer, the auditor did not accept this as evidence of in learning on day one and said had this been a legitimate formal audit, would deduct funding. 

What are your thoughts and counter arguments please?

Kelly Knights

That is allowed for distance learning provision under AEB but I'm not sure about Apprenticeships  - I'm guessing their thinking is how do you know they actually did anything on that day.  Maybe you could change your process and do some work with them on a unit etc, not talk through them what units are covered etc as that is really induction topics. It's a diffficult one I know. 

Jaci Littlewood

That's what we are doing now.  But with Covid etc we were doing more training online and signing up remotely, so not sure where we stand with this.