Advocacy Recommends DOL Complete Additional Small Business Analysis on Apprenticeship Rule

On January 17, 2024, the U.S. Department of Labor Employment and Training Administration (DOL) published a comprehensive rule that seeks to modernize the regulations for the government-registered apprenticeship program. The proposal requires small business sponsors and employers that utilize the apprenticeship program to comply with new operational changes, recordkeeping requirements, and legal disclosures. On March 18, 2024, the Office of Advocacy (Advocacy) filed a comment letter recommending that the Department publish a supplemental initial regulatory flexibility analysis (IRFA).

  • The proposed rule’s IRFA is deficient because it does not properly inform the public about the economic impact of this rule on small businesses. The rule does not present enough data on the number of small entities affected by this rule, or the breakdown of the economic impact of this rule on these entities by industry and revenue size.
  • DOL’s IRFA also underestimates the compliance costs of this rule. Small sponsors and employers will have a difficult time complying with the new costs and administrative burdens in this proposal. This rule will also discourage new small businesses from participating in this program, creating a barrier to entry to lucrative government funding opportunities.
  • Advocacy recommends that the DOL reassess the compliance costs from this rule in a supplemental initial regulatory flexibility analysis and consider significant alternatives that would minimize the economic impact of this rule for small firms.

For more information, please contact Assistant Chief Counsel Janis Reyes at or 202-798-5798.


Comment Letter – National Apprenticeship System Enhancements (PDF, 133 KB)

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