The National Apprenticeship Act (NAA)
As federal policy and priorities have shifted, state leadership is crucial in shaping the future of Registered Apprenticeship. Employers continue to seek predictability and consistency once provided by federal guidance. Now, states must innovate, collaborate, and uphold high-quality standards and effective apprenticeship programming to drive year-over-year growth and improvement in Registered Apprenticeship programs. The National Apprenticeship Act (NAA)
The National Apprenticeship Act (NAA)
The Act, which has guided our national system of apprenticeship, has been collecting dust for nearly 90 years since its implementation in 1937. Still, over the past ten years, the Department of Labor and State Apprenticeship Agencies have overseen a significant expansion of Registered Apprenticeship Programs, growing them by 85 percent. Americans are increasingly eager to build apprenticeships in fields from plumbing to cybersecurity. In 2025, more apprentices will be employed than students at the nine largest US public universities.
Yet, state-by-state variations result in different policies for employers navigating the Registered Apprenticeship system. To expand apprenticeships and maintain quality, policymakers should ensure that current programs can continue to thrive and that new industries can adopt the apprenticeship model.
This brief offers findings from exploratory research to understand the policies of the national apprenticeship system. We focused on four policies: supervising apprentices, hiring, recordkeeping, and wages. We found that, while these systems were generally aligned on recordkeeping and wage progression, differences in Equal Employment Opportunity implementation and supervision of apprentices introduce challenges to national adoption. To strengthen national apprenticeship governance, we recommend policy alignment between the registration agencies, provision of clear guidance on supervising apprentices to include quality and safety, and setting wage benchmarks to ensure apprentices do not journey into occupations paying below the poverty line
Policy Recommendations for State Apprenticeship Agencies
The National Apprenticeship Act of 1937 provides little detail on how a bifurcated system of SAAs and federally operated states should organize a national apprenticeship system that supports high-quality apprenticeships for workers and businesses. Moreover, an update on the 2009 29 CFR Part 29 (Labor Standards for Apprenticeships) regulation is sorely overdue to support a more robust and high-quality experience in Registered Apprenticeship.
From our research we found that it is incumbent upon USDOL and states to create clear and consistent experiences for sponsors through policymaking and practice. We identified the following policy strategies and practices that would enhance transparency and consistency in the apprenticeship system for workers and employers alike:
Apprentice supervision:
States and OA should provide clear guidance online and forms for requesting expanded ratios of apprentice supervision. For states considering expanded ratios, flexibility in ratios can be provided to low-hazard occupations. Records on worker safety can support the sponsor’s justification for expanded ratios, and data provided by the Bureau of Labor Statistics on workplace injuries, hazardous occupations, and apprentice completion rates. For monitoring supervision, states could implement compliance measures, including anonymous reporting and apprentice interviews, to determine whether sponsors are implementing safe and quality supervision.
Selection and recordkeeping:
Recordkeeping requirements and checklists for sponsors should be clear, transparent, and easily accessible online for sponsors and employers. Although the registration agencies have guidelines for recordkeeping, specific and transparent requirements for maintaining apprentice records could improve clarity for employers.
Wages:
Since the National Apprenticeship Act of 1937, national regulations and policy regarding wage progression for apprentices becoming journey workers have not been clear for sponsors or states. Therefore, registration agencies should provide clear information on progressive wage requirements, especially for multiyear apprenticeship programs. Registration agencies could also clarify through guidance documents whether fringe benefits can be used as pay increases to support employer flexibility in meeting progressive wage requirements
Living wages:
To ensure skill progression is rewarded, agencies could require that apprentices in multiyear apprenticeship programs receive at least one yearly wage increase. Finally, states may consider setting wage benchmarks or creating information for sponsors to ensure sponsors and employers do not train workers in occupations that result in wages below the poverty line. Given limited financial and human resources, states should focus on supporting employers’ programs that provide family-supporting wages.
EEO monitoring:
States and OA should ensure clear communication to sponsors. Training for staff and intermediaries on all Equal Employment Opportunity (EEO) aspects through written materials and online resources. Many resources for states and sponsors on anti-harassment and EEO were removed from Apprenticeship.gov in February 2025. It is unclear if this information removal is a permanent change.
Universal outreach:
States should leverage online tools, like the Universal Outreach Tool, to build partnerships with organizations serving underserved populations. Further collaboration with US DOL and registration agencies is required. To improve the database of state organizations that can recruit talent for open apprenticeships.
Anti-harassment training:
States and OA should provide online compliance resources such as instructional videos and assessments. To ease the ability of sponsors to deliver the training to apprentices, trainers, and coworkers.
EEO complaint handling:
States must establish clear reporting protocols in collaboration with their state agency or the US Equal Employment Opportunity Commission. States where apprenticeship agency cannot manage discrimination complaints have specific memoranda of understanding (MOUs). With human or civil rights agencies to handle such complaints.
Source: The National Apprenticeship Act (NAA)
State-Level Policies Develop Skilled
Workforces through Registered
Apprenticeship Programs
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About the Authors
Zach Boren, Senior Fellow, has spent nearly two decades shaping U.S. workforce policy and supporting employers in building high-quality apprenticeships. At Urban, he leads federal, state, and philanthropic projects to expand and modernize apprenticeships nationwide. Previously, he was Chief of Registered Apprenticeship and Policy at the US Department of Labor. Featured in US News & World Report, Bloomberg, NBC News, RealClearPolitics, and the Pittsburgh Post-Gazette.
Shruti Nayak is a policy analyst in the Work, Education, and Labor Division at the Urban Institute. She focuses on apprenticeships, workforce development, and jail reform. Before joining Urban, she interned at the Brookings Institution in the Governance Studies program. Nayak graduated summa cum laude with honors from the Ohio State University. Earning a BA in political science and public policy analysis.