The Inflation Reduction Act (IRA) sets federal requirements for apprenticeships, but some states add their own rules that apply in addition to IRA compliance. Contractors working across state lines need to understand how both sets of requirements interact.
Federal vs. State Requirements
Federal (IRA): Applies nationwide. Requires at least 15% of labor hours from registered apprentices, daily ratio compliance, and participation rules.
State Rules: Some states impose additional apprenticeship, wage, or reporting requirements that stack on top of IRA rules. You must comply with both.
Reciprocity Requirements
If your program sponsor is registered in one state but your project is located in another, you may need to request reciprocity to perform work with registered apprentices.
For Apprentix Fractional Sponsor clients, our program is registered in Texas. That means reciprocity must be granted in every other state or territory where your apprentices will work.
Without reciprocity approval:
Apprentices cannot be recognized as registered in that state.
Their hours will not count toward IRA compliance.
They may not legally perform work on the project.
Each state has its own reciprocity process. Apprentix manages this process on your behalf once you submit a request.
Examples of State-Specific Variations
California & New York: Do not grant reciprocity to out-of-state sponsors. Contractors must register apprentices directly with in-state programs.
Other States: May require unique journeyman-to-apprentice ratios, extra reporting, or additional documentation before granting reciprocity.
Why This Matters
Meeting federal IRA requirements is not enough without state approval.
If reciprocity is denied or delayed, apprentices cannot work — and their hours cannot be counted.
Noncompliance with state rules can put tax credits at risk and delay project schedules.
Best Practices
Always confirm requirements with the Office of Apprentices (OA) or State Apprenticeship Agency (SAA) where your project is located.
Submit reciprocity requests early to prevent delays.
Use Apprentix to track and store federally required compliance documents.
Fractional Sponsor clients can rely on Apprentix’s compliance team to handle reciprocity submissions.
Related: How to Submit a Reciprocity Request