Learnerships and BBBEE Compliance:
Many organisations still view learnerships primarily as a BBBEE compliance exercise. That mindset misses the bigger opportunity. Well-designed learnership programmes do far more than contribute towards the Skills Development element of the BBBEE scorecard. They help organisations build sustainable talent pipelines, develop scarce skills, improve workforce capability and create meaningful employment opportunities for young South Africans.
The most successful programmes are those that combine:
- Strategic workforce planning
- Effective learner recruitment and assessment
- Quality workplace experience
- Strong governance and compliance
- Accurate BBBEE evidence management
- A clear focus on learner absorption
When learnerships are aligned with business objectives rather than simply year-end compliance targets, they deliver lasting value for both employers and learners.
Our latest article explores what every South African employer should know about learnerships and BBBEE compliance, including common pitfalls, best practices and practical considerations for maximising business value.
What You Need to Know
Learnerships are often discussed in terms of BBBEE points, but their real value is broader than compliance. When they are designed properly, learnerships can help South African organisations build work-ready capability, strengthen youth employment pathways, improve skills development outcomes and create a defensible evidence base for B-BBEE verification.
A learnership is a work-based route to a qualification, combining structured practical workplace experience with structured theoretical training. The Department of Employment and Labour also notes that a learnership agreement must be signed by the learner, employer and training provider, and registered with a Sector Education and Training Authority, or SETA.
For employers, the key question is not simply: “How many learners do we need?” The better question is: “How do we design a learnership programme that supports compliance, produces credible evidence, creates useful capability and gives learners a meaningful pathway into work?”
Why learnerships matter for BBBEE compliance
Under the B-BBEE General Codes, learnerships sit within the Skills Development element. The Skills Development scorecard includes expenditure on learning programmes for black people, bursaries for black students at higher education institutions, learning programmes for black employees with disabilities, and participation by black people in learnerships, apprenticeships and internships.
For generic entities, the scorecard includes a 5% compliance target for the number of black people participating in learnerships, apprenticeships and internships as a percentage of total employees. It also provides bonus points for the absorption of black people at the end of an internship, learnership or apprenticeship programme.
This matters because Skills Development is also a priority element. A measured entity must achieve at least 40% of the total weighting points for Skills Development, excluding bonus points, and non-compliance with the threshold can result in the overall B-BBEE status level being discounted.
In practical terms, learnerships can influence BBBEE compliance in four ways:
They can contribute to the learnership, apprenticeship and internship headcount target. They can support legitimate Skills Development spend where costs meet the requirements. They can create potential absorption bonus points when learners are retained into long-term employment. They can also demonstrate that the organisation is investing in structured, work-based learning rather than once-off training activity.
What makes a learnership BBBEE-ready?
A learnership should not be treated as a procurement exercise where the employer simply appoints a provider and waits for a certificate. To be BBBEE-ready, the programme needs structure, governance, documentation and a clear link between learning outcomes and workplace experience.
1. SETA registration and valid agreements
A compliant learnership starts with the correct agreement between the learner, employer and training provider. The employer must provide a job or workplace opportunity for a specific period, practical work experience and time for the learner to attend classes. The training provider must provide education, training and learner support. The agreement must be registered with a SETA.
A compliant learnership starts with the correct agreement between the learner, employer and training provider. The employer must provide a job or workplace opportunity for a specific period, practical work experience and time for the learner to attend classes. The training provider must provide education, training and learner support. The agreement must be registered with a SETA.
2. Alignment with the Skills Development scorecard
Employers should map the programme against the relevant scorecard before implementation starts. This includes confirming which code applies to the organisation, what the measurement period is, whether a sector code changes any requirements, and how the learner cohort supports the organisation’s Skills Development target.
The General Codes also require a SETA-approved Workplace Skills Plan, Annual Training Report and PIVOTAL Report for the measured entity to receive points under the Skills Development element, alongside implementation of priority skills programmes, particularly for black people.
3. Accurate evidence from day one
BBBEE verification is evidence-led. Employers should build the evidence file as the programme runs, not after it ends. This includes signed learner agreements, proof of SETA registration, learner IDs, employment contracts where relevant, training provider accreditation records, attendance registers, progress reports, invoices, payroll or stipend records, assessment results, completion evidence and absorption records.
The Codes also require a trainee tracking tool for entities to score under the absorption bonus indicator. If fewer than 100% of trainees are absorbed, the percentage achieved is recognised.
4. Legitimate and recognisable training expenditure
Not every cost connected to a learning intervention will automatically count. The Codes recognise legitimate expenses incurred for learning programmes, evidenced by invoices or appropriate internal accounting records. They also place limits on certain categories: informal and workplace learning expenditure cannot exceed 25% of total Skills Development expenditure, while legitimate training costs such as accommodation, catering, travelling and Skills Development facilitator or training manager costs cannot exceed 15% of total Skills Development expenditure, subject to specific exceptions.
Salaries or wages paid to employees participating as learners may constitute Skills Development expenditure where the learning programme is a learnership, internship or apprenticeship in Category B, C or D of the Learning Programme Matrix.
5. A real absorption strategy
Absorption is not just a completion certificate or a vague intention to employ. Under Schedule 1 of the Codes, absorption refers to the measured entity’s ability to secure a long-term contract of employment for the employee, learner, intern or apprentice.
That means organisations should plan early for what happens after completion. Which learners could be placed internally? Which suppliers, clients or partner organisations might need entry-level talent? What roles could be created through planned workforce growth? Which learners need additional coaching to become employable?
The best programmes do not leave absorption until the final month. They use the full learning period to assess performance, build work-readiness, identify role fit and prepare learners for realistic employment pathways.
The financial picture: points, tax and funding
Learnerships can create value beyond the BBBEE scorecard, but employers should approach the financial case carefully.
SARS Interpretation Note 20 confirms that Section 12H provides additional deductions to employers for qualifying learnership agreements entered into before 1 April 2027. These deductions include an annual allowance and a completion allowance, and the amount depends on factors such as the learner’s NQF level and whether the learner is a person with a disability.
SARS also confirms that the allowance is available for qualifying learnership agreements registered with a SETA and entered into before 1 April 2027. Employers should obtain tax advice before relying on any deduction, because the claim depends on the specific facts, documentation and timing of the agreement.
SETA funding or grants may also be available in some cases, but these should not be treated as guaranteed. Funding windows, requirements and approval processes vary. A well-managed programme should be financially modelled on conservative assumptions and designed to deliver business value even where incentives or grants are delayed.
Common mistakes employers should avoid
One of the most common mistakes is starting too late in the BBBEE measurement cycle. Learnerships need recruitment, contracting, registration, workplace placement, learning delivery, supervision, assessment and evidence management. A rushed programme increases compliance risk and reduces learner value.
Another mistake is treating learnerships as a paper-based scorecard exercise. Learners need meaningful work, supervision, coaching and feedback. Without these elements, completion rates, learner engagement and absorption outcomes can suffer.
A third mistake is poor record keeping. Even a good programme can be weakened if the evidence file is incomplete. Verification teams will need to see that the learners existed, were eligible, were properly contracted, participated in the programme, received the required learning and workplace exposure, and completed or progressed as claimed.
Employers should also avoid assuming that completion automatically equals absorption. Absorption requires the right employment outcome and evidence. It should be designed into the programme from the start.
A practical employer checklist
Before launching a learnership programme, employers should work through seven questions.
What B-BBEE code and measurement period apply to the organisation? What Skills Development points are realistically available? Which occupations, departments or business units need entry-level capability? Which learners should be recruited, and what eligibility criteria apply? Which accredited provider and SETA processes are required? What evidence must be collected monthly? What absorption or exit pathways will be available at the end?
These questions move the programme away from a compliance scramble and towards a structured workforce development intervention.
How Duja Consulting supports learnership implementation
Duja Consulting supports organisations with the complexity of learnerships, internships and graduate programmes by helping clients design and implement programmes that address specific skills development needs. Duja’s services include recruitment, assessment, matching, placement, programme design, training, practical experience and post-completion placements. The firm also states that it understands SETA, SARS and BBBEE reporting requirements and records information to meet those requirements.
This is important because successful learnerships require more than training delivery. They require programme architecture, candidate selection, learner support, host coordination, evidence management, reporting discipline and a clear view of post-programme outcomes.
For organisations that want to reduce implementation risk, Duja Consulting can assist with designing a programme that balances BBBEE compliance, learner development and business capability.
FAQ: Learnerships and BBBEE compliance
Do learnerships automatically improve a BBBEE score?
No.
Learnerships need to be properly structured, registered, implemented and evidenced. They must align with the applicable B-BBEE code, Skills Development targets and verification requirements.
Must a learnership be registered with a SETA?
Yes.
The Department of Employment and Labour states that learnership agreements must be registered with a SETA, and a learnership agreement is a contract between a learner, employer and training provider.
What is the absorption bonus?
The Skills Development scorecard provides bonus points for black people absorbed at the end of an internship, learnership or apprenticeship programme.
Absorption requires a long-term contract of employment, not merely an intention to employ.
Are there tax benefits for learnerships?
There may be.
Section 12H provides annual and completion allowances for qualifying registered learnership agreements entered into before 1 April 2027, subject to the requirements explained by SARS. Employers should confirm the details with a tax adviser.
Final thought
Learnerships should not be seen as a last-minute BBBEE points exercise. When they are designed with purpose, they help organisations build talent pipelines, develop scarce skills, support transformation and create measurable workplace outcomes.
For employers, the opportunity is clear: move from compliance activity to capability-building. With the right planning, governance and learner support, learnerships can contribute to BBBEE compliance while creating real value for the organisation and for the learners entering the world of work.
Discuss your learnership and BBBEE Skills Development strategy with Duja Consulting.