A learner who has no smartphone is not a compliance problem.
This is counter-intuitive for anyone who moved to digital attendance believing that a signature on a screen had become the rule. It has not. What a funder, a corporate client or an auditor needs is to be able to establish that the course took place and who attended it. A signature, on paper or on a screen, is one way of producing that evidence. It is not the evidence itself, and the smartphone is only one way of producing the signature.
So the problem is real, but it is not where people look for it. It is organisational, and it is solved with organisational means.
Why the question arises anyway
Because an attendance system produces a chain: a person, a date, a half-day, a trainer, a session. The learner without a phone does not break the chain in principle; they break the one you had planned, the one that ran through their device.
You therefore need to give them another one, which produces the same links. Not an exemption: another route to the same point.
The three routes
A device in the room. A tablet or a laptop placed by the door, on which the learner identifies themselves and signs like everyone else. This is the cleanest solution, because it creates no special arrangement: the record produced is identical to the others, and nothing in the file sets this person apart. Cost: one device, and someone who remembers to put it out.
A link sent by email. The learner opens the message from any computer, their own, their employer's or the centre's, and confirms their attendance. The record remains named and timestamped. This route only assumes that they have an email address and access to a computer.
Paper, attached to the session. A sheet signed by hand, immediately attached to the session in the file, and not filed away in a separate binder. This is perfectly acceptable, on one condition that is not decorative: the paper must join the same chain as everything else, with the same date and the same session reference. An orphan sheet in a cupboard proves no more than a missing sheet.
The fourth route, the one not to take
It exists, and it is tempting: have a neighbour sign, or sort it out later.
It fails for a reason that has nothing to do with morals. A signature made by someone else, or made after the fact, breaks the link between the person and the moment, the only link the whole system exists to establish. You end up with a complete document that no longer proves anything, and which, when the file is checked, casts doubt on the sheets around it. That is the hidden price of the arrangement: it does not weaken one line, it weakens the file.
An order of magnitude
Suppose that, in a group of twelve, one or two learners have no usable device on a given morning: a flat battery, a locked company phone, a device too old for the app. That is one or two minutes of handling if the fallback route has been planned, and a quarter of an hour of discussion if it has not.
Over an intake of eight groups, the difference is counted in hours: at thirteen minutes saved per case and one or two cases per group, somewhere between one hour and three and a half hours, and it comes back with every new intake.
What to take away
Plan the fallback route before the first session, not on the morning the case arises. An organisation that has an answer ready handles the incident without thinking about it; one that does not improvises, and improvisation produces precisely the documents that prove nothing.
Sources
This article cites no legal text. Its argument rests on what links an attendance record must establish, and on field orders of magnitude presented as such.