Not every hour worked by an apprentice counts toward the Inflation Reduction Act’s (IRA) apprenticeship requirements. Knowing when hours are disqualified helps you avoid gaps in compliance and prevents unexpected penalties.
Situations Where Hours Don’t Count
Apprentice is not registered
Only apprentices formally registered in a U.S. DOL-approved program can be counted. Unregistered workers—even if called “apprentices”—do not qualify.
Apprentice works without supervision
The IRA requires a 1:1 apprentice-to-journeyman ratio (unless your program standards say otherwise). If apprentices work without a journeyman onsite, their hours don’t count.
Ratio violations
Example: 3 apprentices and 1 journeyman onsite. The extra 2 apprentices must be paid at journeyman rates, and their hours don’t count toward the 15% requirement.
Out-of-scope work
Apprentice hours only count if they are performing tasks within their registered occupation standards. Hours doing unrelated work may not qualify.
Apprentice not on payroll
Apprentices must be W-2 employees. Hours worked by 1099 workers or laborers who haven’t been converted into registered apprentices don’t count.
Canceled or inactive apprentices
If an apprentice’s registration is suspended, canceled, or inactive, their hours logged after that status change are not valid.
What Happens if Hours Don’t Count?
The apprentice must be paid the full journeyman wage for those hours.
Those hours will not contribute toward the IRA’s 15% labor-hour requirement.
Falling short of compliance may trigger financial penalties.
Best Practices
Confirm apprentices are registered and active in Apprentix.
Match apprentice hours with certified payroll to prove compliance.
Monitor daily ratios to prevent disqualification.
Keep agreements, Davis-Bacon certificates, and wage schedules updated in Apprentix.
Quick FAQ
Do travel hours count?
No. Travel time does not count toward apprenticeship labor hours.
If my apprentice works unsupervised for part of the day, do all their hours get disqualified?
Yes. Ratio compliance is measured daily, so all hours for that day won’t count.