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Yes, and as I posted in AnyAnswers (though it appears to have passed everyone by) the draft legislation does not restrict the levy to large employers.
The Levy Allowance is restricted to one company where there are connected companies in the same way that employment allowance is restricted. There is nothing that I can see in the draft legislation that implies that the levy allowance can be aggregated across connected companies.
As drafted, this means that small groups with a couple of employees across connected companies will have to pay the apprenticeship levy, making a mockery of the "no employers with a pay bill of less than £3,000,000".