I can confirm that there are no significant consequences, it just alters when you get the income. For various reasons, we get apprentices not going in the ILR until 3 or 4 months after their start date (more often an ILR error we can’t fix rather than a late enrolment). You just get multiple payments in the first month it goes in the ILR, and levy payers get a lump multiple payment withdrawn in one go. If the normal levy payment would be £100 a month, and they first go in the ILR 3 months late, the first payment will be £400. It’s not good for levy employers, as it makes managing their funds harder.
It is thought that the reason for the timely requirement for starts is to avoid the consequences at year end where any late entry for a start in R12 which is not entered by R14 will result in a loss of funding.
With the introduction of funding from a Levy account it is now even more important that Providers and Employers are aware of the same implications that could apply at year end.
I have found that where a Provider records data for Enquires, Applications and actual starts on their MI system and only flag for inclusion in the ILR when the actual start is confirmed that issues with timely inclusion for starts in the ILR are generally avoided.
Good point. If you don’t get an 18/19 start on the ILR by R14, you won’t get any of the 18/19 funding. If a June start didn’t go in the ILR until November, you’d get the Aug-Nov payments, but not the Jun-Jul payments.