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I think it's unduly prescriptive, but the rules do say you must extend the duration;
P36 If, at the beginning of the programme, the apprentice works fewer than 30 hours a week you must extend the expected duration of the apprenticeship on the ILR (pro rata) to take account of this. You must work with the employer to make sure that the dates on the apprenticeship agreement and training plan are also extended.
By the sounds of it she will achieve early, which is absolutely fine (save for her appearing on the 22A-511 PDSAT) and you'll just get a much bigger balancing payment
Extending the duration for PT workers
We have a potential apprentice for a level 6 HDA. Currently she works 22 hours per week. The employer is 100% committed to giving her 6 hours a week for off-the-job learning, so her week will consist of 16 hours work and 6 hours study time.
Both employer & apprentice are adamant they do not want the length of her programme to be extended.
Is that acceptable to get written confirmation from the employer and not extend the programme dates to account for her doing under 30 hours per week?