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Frequently Asked Questions About Group Sponsors’ Obligations Under the Apprenticeship Equal Employment Opportunity Regulations

June 1, 2022

At a Glance

In a group sponsorship, apprentices work for participating employers rather than for the sponsor itself. These FAQs address a group sponsor’s obligations to ensure that its apprenticeship program complies with equal employment opportunity regulations.

Donna Lenhoff Principal, Donna Lenhoff Associates

Some Registered Apprenticeship (RA) programs are structured as group programs—meaning that the apprentices enrolled in them do not work for the sponsor, but instead work for the employers that participate in the apprenticeship program. These participating employers are the apprentices’ employers of record and are responsible for the apprentices’ on-the-job training; it is their journey-level employees who provide the apprentices with day-to-day oversight and on-the-job instruction.

Sponsors of group programs may be unsure about their obligations to ensure that the equal employment opportunity regulations governing apprenticeships are being followed.

All Registered Apprenticeship programs must follow U.S. Department of Labor regulations found in Parts 29 and 30 of Title 29 of the Code of Federal Regulations (CFR) (or state counterparts). Known as the “Apprenticeship EEO” (equal employment opportunity) regulation, these regulations prohibit RA programs from discriminating against apprentices or apprenticeship applicants on the basis of “race, color, religion, national origin, sex, sexual orientation, age (40 and older), genetic information or disability.” Title 29 Part 30 also requires RA programs to take certain affirmative steps to ensure equal employment opportunity (EEO).

The FAQs in this document offer answers to frequently asked questions from RA sponsors that work with more than one participating employer.

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