This article answers the most common questions about apprenticeship participation, ratios, logging hours, and reporting.
Do we need an apprentice if we have 3 or fewer workers?
If you have 3 or fewer individuals on a project in a laborer occupation, you do not trigger the Inflation Reduction Act's Participation Requirement.
That means you are not required to have a registered apprentice.
👉 However, your hours still count toward the project’s total. The IRA requires 15% of all project hours to be performed by registered apprentices, so contractors who did trigger the requirement may need to cover additional hours.
What if we have 4 or more workers?
Yes — with 4 or more individuals, the Participation Requirement is triggered.
At that point, the ratio requirement applies: 1 journeyman for every apprentice onsite each day.
Example: A 4-person crew would be 2 journeymen + 2 apprentices, not 3 journeymen + 1 apprentice.
Foremen and supervisors typically qualify as excluded roles under this provision, as they are generally considered to perform supervisory or administrative functions rather than direct construction, alteration, or repair work.
Therefore, Foremen and Supervisors do not count toward the threshold of four individuals that triggers the requirement to hire at least one qualified apprentice.
What if we have an apprentice on a crew of 3 or fewer?
If you include a registered apprentice even without triggering the requirement:
Their hours must be tracked in Apprentix.
Payroll records must show apprentice hours to prove compliance with the ratio requirement and percentage rules.
How do we allocate apprentice time across classes and competencies?
Allocation is subjective at the category level (classroom vs. competencies).
The total weekly hours must match payroll, but you do not need to match payroll line-by-line per competency or class.
Typical allocation:
3 hours classroom (reading, meetings, OSHA, training)
37 hours competencies (on-the-job training)
Do travel hours count toward apprenticeship hours?
No. Travel hours do not count toward apprenticeship time or payroll allocation for compliance purposes.
Do we log hours daily or weekly?
Log weekly, not daily.
Use the last day of the pay period as the entry date (e.g., Friday if that ends the pay period).
Always include in the Notes field:
“Matches payroll MM/DD/YY – MM/DD/YY”This shows auditors your apprenticeship hours align with payroll records.
Can a subcontractor serve as a registered apprentice or journeyman?
A registered apprentice is a full-time employee which means they must be a W2 employee for your company in order for them to be registered. Subcontractors cannot be registered under your company as apprentices.
However, a journeyman is allowed to be a subcontractor provided the subcontractor's journeyman is under the same classification as the registered apprentice.
Can we share apprentices or borrow apprentices from another company?
Yes, sharing and borrowing apprentices is allowable but it depends on the situation.
Situation A: You want to share or borrow apprentices and have those hours count towards the apprentice's program.
You are allowed to share your apprentices with another company and borrow apprentices from there. As long as the work being performed is aligned with the apprenticeship occupation, the apprentice gets credit for the time worked towards their apprenticeship program.
Situation B: You want to share or borrow apprentices and have those hours count towards meeting the Inflation Reduction Act's apprenticeship requirements.
No, those apprentice hours do not count towards the Inflation Reduction Act's apprenticeship hours requirement. Under the Inflation Reduction Act (IRA), Company A cannot share its registered apprentices with Company B to satisfy Company B's apprenticeship requirements, even if Company B shares a journeyman with Company A in return. The IRA's apprenticeship provisions require that qualified apprentices be individuals employed by the taxpayer, contractor, or subcontractor performing the relevant construction, alteration, or repair work on a qualified clean energy facility or project.
How many classroom hours are required?
You are required to have 144 classroom hours per 2,000 on-the-job hours.
Can apprentices be registered under more than one classification at the same time?
No, apprentices registered under Apprentix as the program sponsor, cannot be registered in more than 1 occupation at a time. For example, you cannot have a person registered as a Craft Laborer apprentice who is also registered as an Electrician apprentice. You can only register an apprentice into one occupation at a time and transfers from one occupation to another are allowed upon request.