Table of contents 1.Introduction Purpose and scope of the evaluation 2.What was the expected outcome of the quality framework of traineeships (qft)? 2.1 Description of the QFT and its objectives 2.2 Points of comparison 3.How has the situation evolved over the evaluation period? 4.Evaluation findings 4.1.To what extent was the QFT successful and why? 4.2.How did the QFT make a difference and to whom? 4.3.Is the QFT still relevant? 5.Conclusions and lessons learned 5.1 Conclusions 5.2 Lessons learned Annex I: Procedural Information Annex II. Methodology and Analytical models used Annex III. Evaluation matrix

Annex IV. Overview of benefits and costs Annex V. Stakeholders consultation - Synopsis report Annex VI. Research questions of the evaluation study Annex VII. The principles of the 2014 Quality Framework for Traineeships (QFT)



Table of figures Figure 1 - QFT intervention logic Figure 2 - EU-27 average unemployment, NEET and long-term unemployment rate (15-29 years old), 2008-2014 Figure 3 - EU27 average unemployment, NEET and youth long-term unemployment rate (15-29 years old), 2014 - 2021 Figure 4 - Share of young people (aged 20-29 years) estimated to potentially take up an OMT by EU Member State, 2014 and 2020, ordered by 2020 values from low to high Figure 5 - Application of the QFT on the ground across the EU (country map) Figure 6 - Trainee survey: job offers at the end of a traineeship, by sector Table of tables Table 1 - Regulatory approaches in 2014 Table 2 - Comparison between the 2013 Eurobarometer and the 2022 trainee survey Table 3 - Regulatory approaches to traineeships in EU Member States Table 4 - Conformity with QFT principles – OMTs

Table 5 - Conformity with QFT principles – ALMP Traineeships Table 6 - Financial incentives in Member States



Glossary Term or acronym Meaning or definition ALMP traineeships Traineeships as part of active labour market policies (ALMPs), organised by Public Employment Services (PES) in cooperation with employers, based on a tripartite agreement with the aim to help unemployed or inactive young people into employment. Application on the ground The degree to which regulation established is in fact abided by (i.e. practically applied) in traineeships taking place in the country. EFQEA Council Recommendation on a European Framework for Quality and Effective Apprenticeships Conformity The degree to which national legislation regulates traineeships as per the quality standards outlined in the QFT. Cross-border (or transnational) traineeships Traineeships that take place in an EU country other than the EU country where the trainee resides. NEETs Young people neither in employment nor in education and training Open-market traineeships Open-market traineeships (OMTs) are non-mandatory, bilateral, and private agreements agreed between a trainee and a traineeship provider (public/private/non-profit) without the involvement of a third party and without a formal connection to education or training. PES Public employment services QFT (Council Recommendation on a) Quality Framework for Traineeships Traineeships A limited period of work practice, whether paid or not, which includes a learning and training component, undertaken in order to gain practical and professional experience with a view to improving employability and facilitating transition to regular employment YG / Youth Guarantee (Council Recommendation on establishing the) Youth Guarantee 1. Introduction The Council Recommendation of 10 March 2014 on a Quality Framework for Traineeships (2014/C 88/01) (hereinafter QFT) aims at helping young people transition from education, unemployment or inactivity into the labour market through quality traineeships that enhance their skills and allow them to gain work experience. It sets out 21 quality principles for traineeships outside education curricula that can ensure high-quality learning content and adequate working conditions. The QFT is also an important reference point for determining what constitutes a good quality offer of traineeships under the reinforced Youth Guarantee. As emphasised in the European Pillar of Social Rights Action Plan, “[t]raineeships or internships allow to gain practical and first-hand experience. They are usefully facilitating young people’s access to the labour market. Yet, this aim can only be achieved if traineeships are of good quality and apply fair working conditions”. The Action Plan announced that the Commission will “[r]eview in 2022 the Council Recommendation on the Quality Framework for Traineeships, notably as regards working conditions”. The evaluation of the QFT also contributed to the 2022 European Year of Youth. Purpose and scope of the evaluation This report presents the findings of the Commission’s evaluation of the QFT. In line with the Better Regulation Guidelines, it assesses the extent to which the QFT is effective, efficient and coherent, provides EU added value and remains relevant to tackle present needs. Principle 20 of the QFT recommends that Member States “provide information to the Commission by the end of 2015 on the measures taken in accordance with this Recommendation”. Based on the information received, the 2016 Commission Staff Working Document (SWD) ‘Applying the Quality Framework for Traineeships’ analysed the extent of Member States’ conformity with the quality principles of the QFT and pointed out remaining gaps. Its results were used for the present evaluation and are referred to below whenever relevant. The 2016 assessment did not, however, assess the extent to which the quality principles of the QFT were applied on the ground. Moreover, despite the progress made since 2014, the youth unemployment rate remains at nearly double the unemployment rate of the overall labour force (15-64 years), indicating that young people continue to face structural challenges to access the labour market. Given the current geopolitical and macro-economic uncertainties and their impact on the labour market, the central objective of the QFT remains particularly pertinent: the improvement of the quality of traineeships, in particular as regards learning and training content and working conditions, with the aim of easing the transition from education, unemployment or inactivity to work. This evaluation report describes the current situation in the EU in terms of youth employment, the prevalence and quality of traineeships, the extent to which the QFT principles are adequately implemented across the 27 Member States and achieved the expected results. It reports on the main developments between the years 2014 and 2021. The evaluation report also assesses the extent to which the QFT principles are still fit for purpose in light of the current challenges. This includes a reflection on the relevance of quality aspects which are not covered by the QFT. Finally, the evaluation identifies whether traineeships and the implementation of the QFT may have had an impact on youth employment through quality traineeships (in particular learning content and working conditions), as well as on the prevalence of cross-border traineeships. A key limitation of this evaluation report concerns the lack of systematic data collection on traineeships at EU level, in particular on open market traineeships (OMTs). In addition, information on traineeships across the EU is based on varying definitions, which poses problems of comparability for the analysis. Another challenge relates to isolating the impact of the QFT on youth employment from the impact of traineeships in general and of other youth employment measures. While the research conducted in support of this evaluation did not allow to establish a strong relation between the QFT (a non-binding instrument), the extent of its integration in the national legislation or frameworks and the quality of traineeships, some indications of the possible impacts of the QFT on the quality of traineeships and youth employment were found. The limitations outlined above have consequences on e.g. the estimation of traineeship prevalence, the examination of the impact of the QFT on traineeships and the assessment of how well traineeships support the employability of young people. This evaluation is largely based on a dedicated study carried out in 2022 which is built on mapping activities, stakeholder interviews and surveys (both a targeted survey of former, current and potential future trainees, as well as a public consultation). In addition, research and studies on traineeships exist, the results of which have been used in this evaluation. 2. What was the expected outcome of the quality framework of traineeships (qft)? 2.1 Description of the QFT and its objectives

Traineeships, also known as internships, are an important entry point into the labour market for young people. They complement traditional classroom instruction and allow obtaining important skills through practical experience. At the time of adoption of the QFT in 2014, youth unemployment figures had reached all-time highs due to the impact of the global financial and economic crisis. Employment opportunities in general were scarce, and there were concerns that (low quality) traineeships would gain ground, including to substitute regular jobs. A 2013 Eurobarometer survey pointed out that 18% of traineeships did not provide a meaningful learning experience, 23% took place under substandard working conditions, and in effect did not constitute real traineeships but simply low-cost replacements for regular jobs. At the same time, research increasingly confirmed that the value of traineeships in easing the transition to employment depended on their quality in terms of learning content and working conditions. For example, the Impact Assessment accompanying the Commission proposal for the QFT demonstrated a highly significant link between the quality of traineeships and the employment outcome. Quality traineeships bring direct productivity benefits, improve labour market matching and promote mobility, notably by decreasing search and matching costs both for enterprises and for trainees. The Impact Assessment also described the challenge caused by the fragmented, or even lacking, legislation applicable to traineeships in the EU. Furthermore, even where legislation existed, there were notable enforcement challenges. Based on these findings, the Commission proposed the QFT to provide EU-wide quality standards for traineeships and to discourage traineeships with poor learning content or working conditions. The QFT complemented the objectives of the Youth Guarantee, which had been adopted one year earlier to address youth employment in a broader sense. The QFT also contributes to the United Nations’ Sustainable Development Goal (SDG) 8, i.e. to “promote sustained, inclusive and sustainable economic growth, full and productive employment and decent work for all”, by supporting young people’s transition to the labour market whilst providing minimum quality standards. For the purposes of the QFT, traineeships are understood as a limited period of work practice, whether paid or not, which includes a learning and training component, undertaken in order to gain practical and professional experience with a view to improving employability and facilitating transition to regular employment. The QFT applies to Active Labour Market Policy (ALMP) traineeships as well as traineeships offered in the open market (OMTs). The QFT does however not cover work experience placements that are part of curricula of formal education or vocational education and training. Traineeships of which the content is regulated under national law and whose completion is a mandatory requirement to access a specific profession (medicine, architecture, etc.) are also not covered by the QFT. The QFT has the following objectives: to facilitate a smooth transition from education to employment and to increase young people’s employability; to increase the quality and the transparency of the traineeship market ex ante, in order to make it easier for traineeship candidates to screen the offered quality before they make a commitment with a traineeship provider; to increase the awareness of rights and obligations among trainees and traineeships providers; to ensure more coherent regulatory approaches across Member States through common principles to be put in place in national legislation and/or national quality frameworks; to facilitate cross-border traineeships by addressing the need for transparent and clear information in view of the regulatory fragmentation across Member States. The principles of the 2014 QFT The 2014 Council Recommendation asks Member States to: Conclusion of a written traineeship agreement Learning and training objectives Working conditions applicable to trainees Rights and obligations 1.Improve the quality of traineeships, in particular as regards learning and training content and working conditions, with the aim of easing the transition from education, unemployment or inactivity to work by putting in practice the following principles for a Quality Framework for Traineeships: 2.Require that traineeships are based on a written agreement concluded at the beginning of the traineeship between the trainee and the traineeship provider; 3.Require that traineeship agreements indicate the educational objectives, the working conditions, whether an allowance or compensation is provided to the trainee by the traineeship provider, and the rights and obligations of the parties under applicable EU and national law, as well as the duration of the traineeship […]; 4.Promote best practices as regards learning and training objectives in order to help trainees acquire practical experience and relevant skills; the tasks assigned to the trainee should enable these objectives to be attained; 5.Encourage traineeship providers to designate a supervisor for trainees guiding the trainee through the assigned tasks, monitoring and assessing his/her progress; 6.Ensure that the rights and working conditions of trainees under applicable EU and national law, including limits to maximum weekly working time, minimum daily and weekly rest periods and, where applicable, minimum holiday entitlements, are respected; 7.Encourage traineeship providers to clarify whether they provide coverage in terms of health and accident insurance as well as sick leave; 8.Require that the traineeship agreement clarifies whether an allowance or compensation is applicable, and if applicable, its amount; 9.Encourage the concerned parties to ensure that the traineeship agreement lays down the rights and obligations of the trainee and the traineeship provider, including, where relevant, the traineeship provider's policies on confidentiality and the ownership of intellectual property rights; To reach these objectives, the QFT supports the improvement of working conditions and the learning content of traineeships through 21 quality principles which include provisions to enhance transparency of and information on traineeships (see box below). Of these, principles 19 and 20 are considered are considered action points for Member States rather than specific quality elements to be applied to traineeships. They are therefore not assessed as such in the evaluation. The QFT also outlines how the Commission intends to, inter alia, support Member States’ action through EU funds, the exchange of good practices, and monitoring. Reasonable duration Proper recognition of traineeships Transparency requirements Cross-border traineeships Use of European Structural and Investment Funds Applying the Quality Framework for Traineeships 10.Ensure a reasonable duration of traineeships that, in principle, does not exceed six months, except in cases where a longer duration is justified, taking into account national practices; 11.Clarify the circumstances and conditions under which a traineeship may be extended or renewed after the initial traineeship agreement expired; 12.Encourage the practice of specifying in the traineeship agreement that either the trainee or the traineeship provider may terminate it by written communication, providing advance notice of an appropriate duration in view of the length of the traineeship and relevant national practice; 13.Promote the recognition and validation of the knowledge, skills and competences acquired during traineeships and encourage traineeship providers to attest them, on the basis of an assessment, through a certificate; 14.Encourage traineeship providers to include in their vacancy notices and advertisements information on the terms and conditions of the traineeship, in particular on whether an allowance and/or compensation and health and accident insurance are applicable; encourage traineeship providers to give information on recruitment policies, including the share of trainees recruited in recent years; 15.Encourage employment services and other providers of career guidance, if providing information on traineeships, to apply transparency requirements; 16.Facilitate the cross-border mobility of trainees in the European Union inter alia, by clarifying the national legal framework for traineeships and establishing clear rules on hosting trainees from, and the sending of trainees to, other Member States and by reducing administrative formalities; 17.Examine the possibility to make use of the extended EURES network and to exchange information on paid traineeships through the EURES portal; 18.Make use of the European Structural and Investment Funds, namely the European Social Fund and the European Regional Development Fund, in the programming period 2014-2020, and the Youth Employment Initiative, where applicable, for increasing the number and quality of traineeships, including through effective partnerships with all relevant stakeholders; 19.Take appropriate measures to apply the Quality Framework for Traineeships as soon as possible; 20.Provide information to the Commission by the end of 2015 on the measures taken in accordance with this Recommendation; 21.Promote the active involvement of social partners in applying the Quality Framework for Traineeships; 22.Promote the active involvement of employment services, educational institutions and training providers in applying the Quality Framework for Traineeships. To understand how the QFT was expected to work, the intervention logic ( Figure 1 ) outlines the rationale of the intervention and the needs that triggered it. It also describes the objectives and expected outputs and the way how they were supposed to be achieved (actions). Figure 1 - QFT intervention logic





2.2 Points of comparison The points of comparison against which the intervention is assessed, concern young people’s situation on the labour market, the prevalence and quality of traineeships, as well as regulatory approaches at the time of adoption of the QFT in 2014. It is, in particular the parts on the prevalence and quality of traineeships, mainly based on the information provided in the 2013 Impact Assessment accompanying the proposal for a QFT, which in turn largely relied on the 2013 Eurobarometer survey on traineeships. Where possible, the 2013 Eurobarometer survey is directly referenced. Young people’s labour market situation in 2014 In 2014, both the youth unemployment rate (15-29) and the share of young people who were neither in employment, education or training (NEETs) in the EU were high, standing at 18.7% and 15.7% respectively. Both rates had followed an upward trend from the onset of the global financial and economic crisis in 2008 (respectively 12.3% and 13.1%), reaching their peaks in 2013. Although variations between Member States were significant, these figures show the long-lasting impact the crisis had on young people. Figure 2 - EU-27 average unemployment, NEET and long-term unemployment rate (15-29 years old), 2008-2014 Source: Eurostat, youth unemployment rate by sex, age and country of birth; young people neither in employment nor in education and training by sex, age and labour status; youth long-term unemployment rate (12 months or longer) by sex and age Furthermore, the share of young people that were out of work for a prolonged period – 12 months or longer – stood at 7.5% in 2014. It had reached its peak in 2013 at 7.7%, with long-term consequences on young people’s skills and employability, future earnings and well-being. Prevalence of traineeships in 2014 Although official statistics on traineeships do not exist, the 2013 Eurobarometer survey provided some indications on their prevalence. These findings should be interpreted with caution due to limitations on the representativeness of Eurobarometer surveys. The Eurobarometer results indicated that traineeships were widespread around the time of the adoption of the QFT, with 46% of respondents aged from 18 to 35 in the EU having undertaken at least one (and often more than one) traineeship. At the time, experts estimated that the number of traineeships was on the rise. One reason for this trend was that the majority of traineeships was unpaid or low-paid and represented a relatively affordable option for companies in times of crisis. It might also have reflected the lack of better employment opportunities for young people in the context of high youth unemployment. In terms of traineeship prevalence by sector, according to a 2012 Commission study, OMTs were becoming widespread across all sectors. 9% of them had a cross-border nature. The study also found that unpaid or low-paid traineeships were particularly present in the creative (e.g. culture, art, design, publishing) and media/journalism sectors. Furthermore, larger organisations were found more likely to offer traineeships compared to SMEs. However, the SME test which was carried out in 2012-2013 showed that the majority of respondent SMEs (71.9%) did consider traineeships as a way to select and train future employees and highlighted the importance of traineeships for job creation. Quality of traineeships in 2014 Before the adoption of the QFT, the quality of traineeships across the EU presented several areas of concern. The 2013 Eurobarometer results indicated that one in three traineeships was deemed unsatisfactory, either in terms of working conditions (25% of all traineeships), learning content (18%) or both. It also found that 32% of respondents received compensation, and only 41% of these indicated that this was sufficient to cover living costs. The widespread use of unpaid and/or low-paid traineeships entailed the risk of traineeships being abused to replace regular employment. It also raised concerns about equal opportunities, especially for young people from disadvantaged backgrounds. Another common criticism concerned the (frequent) lack of social security and/or health/medical insurance coverage, entitlement to holidays, sick or holiday pay, and pension entitlements. Furthermore, the absence of adequate monitoring was also identified as an element that negatively affected traineeship quality. The aforementioned 2012 Commission study moreover highlighted recurrent weaknesses in the learning content of traineeships. It found that in particular trainees in OMTs were frequently asked to perform tasks which were either irrelevant to their learning needs or perceived as too mundane. The 2013 Eurobarometer highlighted that a lack of information was an important cause for the lower prevalence of cross-border traineeships, with 38% of those who would have been interested in doing a traineeship abroad citing insufficient information on traineeship regulations in other Member States as an obstacle. Lastly, in terms of the extent to which traineeships contributed to fostering the labour market integration of young people, less than a third of respondents to the Eurobarometer (27%) had been offered a work contract after the end of their traineeship by the same employer who provided the traineeship.

Regulatory approaches in 2014 The regulatory approaches to traineeships varied widely across Member States and types of traineeships in 2014 (see Table 1 ). Nine Member States had a specific regulation on traineeships. ALMPs traineeships were more often regulated, as compared to OMTs . While certain Member States (e.g. France) regulated all types of traineeships by law (i.a. forbidding OMTs to ensure that all traineeships are monitored by a third party institution) many other countries did not have in place any specific legislative framework for trainees. Less than half of the then 28 Member States had legislative provisions on traineeships’ duration, remuneration or social protection coverage. Additionally, in 11 Member States there were legislative and administrative barriers to transnational traineeships . Table 1 - Regulatory approaches in 2014 Regulatory approach Traineeships (no distinction made in type of traineeships) Specific regulation on traineeships EE, ES, FI, FR, HU, IT, PT, SI, SK (9) The widely diverse approach to regulation reflected the equally great variety of approaches to defining traineeships and/or trainees. As of 2012, most Member States had either a definition in their legislation or at least reached a common national understanding of the concept of a traineeship. However, this did not result in a homogenous or coherent definition of a traineeship across the EU. Among the common characteristics of traineeships that could be found in legislative frameworks across Member States prior to 2014 were: the general educational purpose; the practical element of learning; and the temporary nature of the traineeship. Some national regulations also addressed aspects related to information on working conditions and rights of the trainee during the traineeship . Even in countries where legislative and regulatory frameworks existed, the presence of these regulations did not guarantee that traineeships were of high quality, due to their inadequate enforcement, particularly in the open market . 3. How has the situation evolved over the evaluation period? Current state of play Young people’s labour market situation While high quality traineeships can help young people in their transition to employment, their situation on the labour market depends on many other factors, above all the economic situation. Before the COVID-19 pandemic began in 2020, the youth employment rate was steadily improving, though the crisis induced by the pandemic interrupted this trend. The information presented below aims to illustrate the context in which the QFT was implemented. Figure 3 - EU27 average unemployment, NEET and youth long-term unemployment rate (15-29 years old), 2014 - 2021 Source: Eurostat (LFSA_URGAN, TESEM150, YTH_EMPL_120) Since the adoption of the QFT in 2014, youth unemployment in the EU followed a decreasing trend from 18.7% to 11.9% in 2019. In 2020, triggered by the Covid-19 pandemic, youth unemployment increased to 13.3%, while slightly decreasing again in the following year to 13%. The NEETs rate in the EU followed the same trend, falling from 15.7% in 2014 to 12.6% in 2019, with a spike in 2020 at 13.8% and decreasing again to 13.1% in the year after. As for long-term youth unemployment, the effect of the Covid-19 pandemic manifested itself with a slight delay, as it followed a downward trend between 2014 and 2020 dropping from 7.5% to 3.2% but rose again to 3.5% in 2021. Though compared to 2014, the labour market situation of young people has improved significantly, the uncertainty on the mid- and long-term impacts of the Covid-19 induced disruptions, the Russian invasion of Ukraine, the energy crisis and the rising costs of living call for caution. Furthermore, the youth unemployment rate remains at almost double the unemployment rate of the overall labour force (15 – 64 years), indicating the structural challenges that young people continue to face. Such challenges include the lack of professional experience compared to older workers, and if hired, being more prone to be employed under precarious conditions including temporary contracts.

Prevalence of traineeships Robust and EU-wide comparable data on the prevalence of traineeships is lacking and therefore, estimations were made. The share of young people estimated to potentially take up a traineeship across the EU has increased from 16.6% in 2014 to 17.2% in 2020. Trainees with educational qualifications below tertiary education are not captured by this estimate. In the 2013 Eurobarometer survey on traineeships , traineeships were found to be more prevalent among university graduates (61%), compared to persons with no tertiary qualifications (40%). The trainee survey (conducted as part of the 2023 study supporting this evaluation) also found that the majority of respondents (973 out of 1,836 (53%)) had tertiary educational attainment when undertaking their traineeship. As is the case with the 2013 Eurobarometer survey, the results of this trainee survey need to be taken with caution, in light of the limited representativeness of such a survey . Based on indications provided by the trainee survey , the difference between women and men seems to have become more pronounced, with women increasingly more likely than men to undertake an OMT. 1,212 out of 1,836 (66%) of female respondents in the trainee survey and 606 out of 1,836 (33%) of male respondents had completed one traineeship after finishing their education. The 2013 Eurobarometer resulted in 49% of female respondents and 43% of male respondents with a traineeship experience . Figure 4 - Share of young people (aged 20-29 years) estimated to potentially take up an OMT by EU Member State, 2014 and 2020, ordered by 2020 values from low to high Source: 2023 study supporting the evaluation. Note: the EU average is calculated using the data from the 20 Member States that have OMTs in their labour market (i.e. excluding Estonia, Finland, France, Italy, Malta, Sweden and Slovakia). There are also indications that cross-border traineeships have become more common since 2014. The trainee survey shows that 363 out of 1,912 (19%) of respondents had undertaken a cross-border traineeship. This may suggest that the number of cross-border traineeships has increased since 2014, as per the objective of the QFT. The QFT refers to the use of the European Job Mobility Portal (EURES) to exchange information on paid traineeships. The 2016 EURES regulation introduced an obligation for Member States to share on the EURES portal information and guidance on (paid) traineeships at national level as from 2018. The trainee survey indicated that 239 out of 1,836 (13%) of respondents made use of the EURES portal to find a cross-border traineeship. Quality of traineeships The main element of the QFT is the written traineeship agreement that indicates the educational objectives, adequate working conditions, rights and obligations, and a reasonable duration for traineeships (see recital 11 of the QFT ). Assessing these quality elements, the 2023 study supporting this evaluation shows that there are indications that the quality of traineeships since 2014 has generally increased. This observation is based on the responses of national stakeholders to targeted consultations, the trainee survey, the vacancy analysis (all three conducted in the 2023 study supporting the evaluation ) as well as to the public consultation carried out as part of this evaluation. The public consultation provided indications that overall the quality of traineeship offers has improved to a large or moderate extent (143 out of 239 respondents (60%)) and that there are more traineeships of good quality (120 of 169 (71%) of respondents in the public consultation). When comparing the outcomes of the 2013 Eurobarometer and the 2022 trainee survey, a more mixed picture emerges: Table 2 - Comparison between the 2013 Eurobarometer and the 2022 trainee survey (carried out under the 2023 study supporting the evaluation) Eurobarometer, European Commission, 2013 Survey of trainees, 2022 (under the 2023 study supporting the evaluation) Trend Learning outcomes 18% of respondents consider they have not learned anything professionally useful during their traineeship (N=3,464). 13% of respondents considered they have not learned anything professionally useful during their traineeship. (N=1,836) Job outcomes 27% of respondents who completed a traineeship were offered an employment contract at the end of their traineeship (N=5,945). 42% of respondents indicated that they were offered a job after their OMTs (N=1,836). Written agreement 35% trainees did not have a written traineeship agreement or contract with the host organisation or company (N=5,945). 17% did not sign such a written agreement. (N=1,836). Transparency 42% of respondents said that the advertisement made clear how much the traineeships was paid 21% of respondents said that the vacancy notice mentioned the amount of the allowance and/or compensation (N=1,836). Certificate or reference letter 64% of respondents stated that at the end of the traineeship the organisation or company gave a certificate or a letter of reference (N=5,945). 68% of respondents reported that they had received either a certificate (32%), a letter of reference (24%) or both (12%) (N=1,836). Duration 15% of respondents stated that their traineeship lasted longer than 6 months (N=5,945). 22% of respondents stated that their traineeship lasted longer than 6 months (N=1,912).

As shown in the table above, compared to 2013, the share of trainee respondents who consider that their traineeship did not result in useful professional skills and work experience decreased to below 20% in 2022. Furthermore, while in 2013, 27% of respondents reported to have been offered a job after their traineeship, this increased to 42% (771 out of 1,836) in the 2022 trainee survey. On the written agreement principle, the share of trainees without such an agreement was much higher in 2013 (38%) than in 2022 (17%, or 312 out of 1,836 respondents). The percentage of respondents indicating to have received a certificate or reference letter also slightly increased. However, based on the two surveys, a negative trend can be observed for the following quality princples: transparancy of (information provided in the) vacancies (i.e. the amount of pay/allowance/compensation) and duration of traineeships. In addition, the 2023 study supporting this evaluation examined almost 2,000 vacancies in the 27 Member States on their alignment with the QFT principles on transparency (i.e. providing information in the vacancy on the terms and conditions of the traineeship). It found a higher alignment for ALMP traineeships compared to OMTs. Vacancies for OMTs in 15 Member States complied hardly or to a low extent with the quality principles on transparency, while this was the case in only six Member States for vacancies for ALMP traineeships. Regulatory approaches Similar to the situation in 2014, the 2023 study supporting this evaluation found that national legislation generally regulates ALMP traineeships to a high degree, but OMTs to a more modest degree. Since 2014, five Member States (BG, ES, LT, LU and RO) adopted legislation on OMTs. 12 Member States (BE, BG, DK, EE, EL, HR, IE, IT, LT, PT, RO, and SK) adopted legislation covering ALMP traineeships. In addition, ALMP traineeships are more likely to be governed by specific laws on ALMPs, whereas OMTs are more likely to fall under general labour law or specific provisions on OMTs, if regulated at all. This is illustrated in the table below: Table 3 - Regulatory approaches to traineeships in EU Member States Regulatory approach 2014 2021 Traineeships (no distinction made between types) ALMP traineeships OMTs Specific measures in the labour code or in dedicated legislative instruments EE, ES, FI, FR, HU, IT, PT, SI, and SK (9) AT, BG, BE, DE, DK, EL, EE, ES, FI, FR, HR, IT, LT, LU, MT, PL, PT, RO, SK, SI, SE (21) BE, BG, DE, ES, FR, LU, LT, RO, PL, PT, SI (11) General labour legislation No information available CZ, HU, LV, NL (4) AT, CZ, DK, EL, HR, HU, IE, LV, NL, SE (10) No regulation No information available CY, IE (2) CY, EE, IT, FI, MT, SK (6) Integration of QFT principles in national legislation or frameworks Based on the 2016 Commission SWD and the 2023 study supporting this evaluation the degree of the reflection of the QFT principles in national legislation or frameworks (i.e. Member States’ ‘conformity’ with the QFT) can be assessed. However, and in particular given the non-binding nature of the QFT, it is not possible to establish a causal link between regulatory developments at national level and the adoption of the QFT. A slight increase in terms of conformity can be observed for OMTs (four Member States fully/mostly aligned in 2016 versus seven Member States in 2021). A larger increase is observed for ALMP traineeships, with 18 Member States fully/mostly in conformity in 2021 versus 15 in 2016. Further analysis can be found in section 4. Application of the QFT on the ground The practical application of the QFT on the ground was assessed as part of the 2023 study supporting this evaluation through a vacancy analysis (comprising 1,972 vacancies on OMT as well as ALMP traineeships in all 27 Member States), desk research and interviews with stakeholders, and the trainee survey. The analysis found that the practical application of the QFT principles is lagging behind their legislative implementation in the majority of Member States, in particular for OMTs. Further analysis can be found in section 4.



4. Evaluation findings The analysis in this section is based on the evidence provided in sections 2 and 3 unless otherwise mentioned. The different research activities carried out in the 2023 study supporting this evaluation (i.e. targeted consultations, mapping and case studies) underpin the assessment of the five evaluation criteria (effectiveness, efficiency, coherence, added value and relevance). In addition, the public consultation conducted by the Commission supports the assessment of four out of five evaluation criteria, i.e. effectiveness, efficiency, added value and relevance. For the following analysis, it is to be noted that the QFT is a non-binding instrument. It cannot be ascertained that changes observed since the adoption of the QFT in 2014 are a direct result of the QFT. Furthermore, the 21 principles of the QFT cannot all be considered “quality principles” as such. Principle 1 is a general recommendation to Member States to improve the quality of traineeships by putting in practice the quality principles of the QFT and principles 19 and 20 are considered action points for Member States rather than specific quality elements inherent to quality traineeships and are thus not assessed as such. 4.1. To what extent was the QFT successful and why?

Effectiveness Integration of QFT quality principles in national legislation and frameworks Since the adoption of the QFT there has been moderate progress in the take up of its quality principles in national legislation and frameworks, with notable differences across Member States and types of traineeships. Since 2014, 14 Member States (BE, BG, DK, EL, EE, ES, HR, IE, IT, LT, LU, PT, RO, SK) have adapted or introduced legislation (either on OMTs or ALMP traineeships or both) integrating quality principles of the QFT in their legislative or policy frameworks. Such changes were more prevalent in national legislation/policy governing ALMP traineeships (identified in 12 Member States), than OMTs (identified in five Member States). In the targeted consultations as part of the 2023 study supporting this evaluation , some stakeholders argued that the legislation in certain Member States may not have been amended since 2014, because traineeship standards are adequately governed by existing legislation or because certain types of traineeships do not exist or are very rare . For example, since the adoption of the QFT, Estonia, Finland, and Malta did not implement legislative changes on OMTs, which are rare in these countries. This underlines that the extent to which the QFT principles have been integrated in national legislation depends on the overarching existing legislative framework for traineeships in the country as well as the (perceived) prevalence and uptake of specific types of traineeships in the labour market. Examples of the integration of the QFT in national legislation Luxembourg - A law specifically putting in place all principles of the QFT was introduced in 2020. Finland - QFT principles are implemented in Finnish legislation on ALMP traineeships. For example, the Finnish work try-out programme describes in detail whether the trainee is entitled to an allowance or compensation, and the amount. In some Member States (e.g. BG, ES, FI, IE) , stakeholders (including youth representatives, PES and national policymakers) expressed the view that the introduction of new policies had led to an improved alignment with the QFT. For example, representatives from both the PES and a youth organisation underlined that the new labour market reform in Spain had increased conformity with the QFT. National policymakers in Bulgaria highlighted that the QFT drove legislative changes in relation to OMTs. The mere fact that changes were made to national legislation or frameworks on traineeships does not mean that national legislation or frameworks have fully integrated all QFT quality principles. Therefore, the extent of the integration of the QFT quality principles has also been analysed, and is hereafter referred to as conformity (see Table 4 on OMT and Table 5 on ALMP traineeships) . For the purpose of this evaluation, the conformity with the QFT principles under the dimensions ‘written agreement’, ‘learning and training objectives’, ‘working conditions’, ‘reasonable duration’, ‘proper recognition’, and ‘transparency requirements was assessed. This assessment builds on desk research and on targeted consultations using a scoring method explained in Annex II Methodology. Table 4 - Conformity with QFT principles – OMTs Source: 2016 Commission SWD and 2023 study supporting this evaluation. Table 5 - Conformity with QFT principles – ALMP Traineeships Source: 2016 Commission SWD and 2023 study supporting this evaluation

A slight improvement in terms of conformity can be observed for OMTs with four Member States fully/mostly aligned in 2016 versus seven Member States in 2021. A larger improvement is observed for ALMP traineeships, with 18 Member States fully/mostly in conformity in 2021 versus 15 in 2016. In 2021, the QFT principles that are most commonly implemented by legislation (either fully or partially) across the EU-27 are the same across OMTs and ALMP traineeships: 1.Trainees' rights and working conditions are respected including limits to maximum weekly working time, weekly rest periods, minimum holiday entitlements (covered in 18 Member States in legislation governing OMTs and in all 27 Member States for ALMP traineeships); 2.The traineeship is based on a written agreement (covered in 17 Member States in legislation governing OMTs and in 27 Member States for ALMP traineeships); 3.The written agreement indicates key information including educational objectives, working conditions, if compensation is provided and how much, rights/obligations of all parties, and the duration (covered in 17 Member States in legislation governing OMTs and all 27 Member States in ALMP traineeships). The QFT principles that are least implemented in legislative frameworks of Member States are also the same across OMTs and ALMP traineeships: 1.Traineeship providers include in their vacancies information on the conditions of the traineeship (this is not implemented at all in six Member States for OMTs and in nine Member States for ALMP traineeships); 2.The duration of the traineeship does not exceed six months (in seven Member States for OMTs and in seven Member States for ALMP traineeships); 3.The knowledge, skills and competences acquired by the trainee are recognised by the traineeship provider through an assessment and a certificate (six Member States do not implement this at all for OMTs and seven Member States for ALMP traineeships). Practical application on the ground While some notable alignment of Member States’ traineeship standards to the QFT could be observed, the practical application of these regulatory standards on the ground is lagging behind in most Member States, notably for OMTs. This assessment is based on the following research elements of the 2023 study supporting this evaluation: ·The analysis of traineeship vacancies for both types (OMTs and ALMP traineeships) in each Member State with regard to their conformity with the transparency principles of the QFT; ·Desk research and interviews conducted with traineeship providers (employers) and other actors involved in the practical application of the QFT (e.g. national authorities); ·Research on the impact of the QFT on trainees and the society, through the trainee survey, desk research and interviews. The study observed that the quality parameters of ALMP traineeships are more closely aligned with Member States’ regulatory frameworks than in the case of OMTs. The practical application of the QFT principles for ALMP traineeships can be considered as low or very low in only two Member States, while all other Member States are assessed to moderately or to a high degree apply the QFT on the ground. For OMTs, the picture (see country map below) is less positive and more diverse with no Member States applying the QFT to a high degree on the ground, nine Member States to a moderate degree, eight Member States to a low extent, three Member States to a very low extent and for the rest (seven), OMTs were found not to be existing or very rare.

As regards the transparency principles of the QFT, a vacancy analysis as part of the 2023 study supporting this evaluation scanned through 1,972 vacancies in all 27 Member States (of which 1,272 were on OMTs and 700 concerned ALMP traineeships). 42% of the analysed OMT vacancies and 59% of the ALMP traineeship vacancies mentioned allowance or compensation. 21% of OMT vacancies and 44% of ALMP vacancies indicated the amount. These results support the view that the application of the QFT principles on the ground is higher for ALMP traineeships than for OMTs. The trainee survey as part of the same study also suggests that the practical application of the QFT principles is higher in certain sectors than in others. For example, most respondents in the sectors ‘Financial and Insurance services’ and ‘Professional, scientific and technical activities’ stated that they had signed an agreement at the beginning of their traineeship (1,469 of 1,836 (80%) and 1,487 of 1,836 (81%) respectively). The QFT quality principles were found to be applied less in sectors such as arts, entertainment and recreation, health and social work, and education. Furthermore, sectors with a larger share of small enterprises were more likely not to apply the QFT principles due to the limited human and financial capacity to handle the administrative burden – or the perceived administrative burden – of ensuring quality traineeships. More generally, a low level of awareness of the QFT principles and the potential benefits of quality traineeships amongst young people and employers alike hampered the QFT reaching its full potential in terms of effectiveness.



Figure 5 - Application of the QFT on the ground across the EU (country map) Monitoring and enforcement Principle 19 of the QFT recommends that Member States take appropriate measures to apply the QFT as soon as possible. However, the monitoring and enforcement of the relevant national legislation governing traineeships is in many cases not fit for purpose. There are substantial variations between the existence and functioning of monitoring and enforcement mechanisms across Member States. Such mechanisms exist in all 27 Member States for ALMP traineeships, while for OMTs, they exist in 14 Member States . The case studies and interviews (as part of the targeted consultations) carried out for the 2023 study supporting this evaluation suggest that even where such mechanisms exist for OMTs, they have a limited impact on ensuring the practical application of regulations. This can be attributed to an insufficient capacity of labour inspectorates or a less systematic monitoring by labour inspectorates where traineeships are regulated as a specific employment relationship (instead of being covered by general labour law, which is more systematically monitored). The decision of the Council of Europe’s Committee of Social Rights on the case brought by the European Youth Forum regarding the possibilities under Belgian law allowing for unpaid internships noted that the “labour inspectorate is not sufficiently effective in detecting and preventing “bogus internships”. Moreover, point 163 of the decision explained that “[t]he Committee found that the inspection system which solely depends on individual complaints by interns, considering their disadvantaged situation, cannot be considered as sufficiently efficient in preventing misuses of unpaid internship contracts in violation of Article 4§1 of the Charter”. A lack of clarity on who is responsible also weakens Member States’ monitoring and enforcement capacities. The 2023 study supporting this evaluation highlighted the cases of Belgium where there are ambiguities on which level of government is responsible and Italy, where a lack of cooperation between different national authorities makes it difficult to carry out controls effectively. In the targeted consultations with national authorities and employers, some (EE and SK) stated that the application of the QFT on the ground is also impeded by a lack of awareness among both trainees and employers about the QFT quality principles (or relevant national legislation which they should observe). In addition, employers highlighted the following obstacles: ·The lack or the complexity of existing relevant legislative frameworks; ·Organisational changes due to the outbreak of the COVID-19 pandemic; ·Difficulties in cooperation between public employment services (PES) and employers, and insufficient PES capacity to properly match trainees with labour market needs. More generally, consultations with EU and national stakeholders (in interviews as part of the targeted consultations) gave indications that the QFT may be lacking practical guidance for employers / traineeship providers on the overall implementation of the QFT. Involvement of relevant stakeholders The QFT (principles 21 and 22) recommends promoting the active involvement of key stakeholders, including social partners, public employment services, education institutions and training providers in applying the QFT. The public consultation carried out in support of this evaluation gave indications that the active involvement of social partners and key stakeholders in implementing quality traineeships was considered very important or important by some stakeholders (i.e. rated as very important by all six trade union respondents (100%), two out of three business associations respondents (66%), important by 32 out of 85 public authorities (38%), 12 out of 34 former or current trainees (35%), and 23 out of 56 academic/research institutions (41%)). This aspect is deemed particularly relevant by social partners, with employer organisations and trade unions valuing stakeholders’ engagement the most (67% and 100% respectively). The involvement of social partners through collective agreements (e.g. AT, FI and ES) tends to focus on working conditions. The case study on Austria observed that improvements for trainees mainly related to establishing a minimum pay in certain sectors (not a QFT principle), but that in the Information Technology sector the collective agreement also required a training plan to be defined (relevant to the QFT principle of defining learning and training objectives). In Finland, trade unions at sectoral level are involved in collective agreements, which also cover traineeships as regards pay, quality issues, rights and working conditions. The case study on Spain found that trade unions regularly engage in negotiations with employer organisations and/or the government in relation to traineeship relevant legislation, such as the recently adopted labour market reform (RDL 32/2021). This reform specifies the need for supervision and individual training plans.

Besides collective agreements, social partners are involved in discussions on regulation and/or policy-making with regards to traineeships (FI, HR, IT, LU, IE) and in monitoring the implementation of policies relevant to traineeships (FI and DK). It was not possible to deduce from the evidence gathered in the 2023 study supporting this evaluation whether such involvement has had an impact on the application of the QFT principles. In all Member States, the case studies and interviews conducted in the targeted consultations found that PES are actively involved in the design, delivery and promotion of ALMP traineeship programmes, at times in cooperation with other national authorities and employers/employer organisations. PES also develop guidance and support for key actors (such as traineeship providers) on how to implement high quality traineeships. Impact on easing labour market transitions Quality traineeships can have a positive impact on young people through increased employability in terms of relevant skills, practical experience and access to professional networks and, as explained earlier, one of the key aims of the QFT is indeed to help young people transition from education, unemployment or inactivity into the labour market. This was confirmed to be the case by the trainee survey , carried out in 2022 as part of the 2023 study supporting this evaluation, where over 80% of respondents (strongly) agree that the tasks they did during their traineeship helped them gain practical experience and relevant skills as well as achieve their learning and training objectives . 771 out of 1,836 (42%) of respondents were offered a job after their traineeship, and 717 (93%) of them reported that traineeship helped them at least to some extent to get a job offer. Even higher starting salaries have been identified in some Member States . The evidence gathered as part of the study does not allow to ascertain the impact of the implementation of the QFT itself on trainees, as it was not possible to determine to which extent the QFT has influenced the legislation. However, the study assessed which of the QFT principles were considered most useful for facilitating young people’s labour market integration based on the views gathered through the trainee survey and interviews conducted in the targeted consultations (see box below). On the QFT principles not mentioned in the box below, the views as to their impact on the labour market integration of young people were less pronounced. QFT principles which are most likely to have a positive impact on labour market integration of young people: Defining learning and educational objectives of the traineeship, including the appointment of a supervisor or a mentor. These elements were highlighted by employer organisations from Italy, Lithuania and Hungary as well as EU level employer organisations and trade union representatives from the Netherlands, Croatia, Bulgaria, France and Poland. In the trainee survey of the evaluation study, 89% of the respondents stated that ‘the possibility of trying out different tasks’ and 85% that ‘having access to training opportunities’ were important/essential for trainees in their traineeship. A written traineeship agreement can be considered a particularly important element. Representatives from public employment services in particular highlighted that having a traineeship contract, with clearly defined educational objectives and standards, helps trainees understand what is expected from them, so that they can meet workplace requirements and increase their chances of obtaining employment following their traineeship. The QFT principle on a written traineeship agreement has, in the view of stakeholders from Estonia, Cyprus, Ireland, Luxembourg, Poland and Slovakia contributed to reducing the exploitation of trainees and to a greater awareness of their rights. The trainee survey conducted as part of the evaluation study also highlighted sectoral differences, with respondents working in arts, entertainment and recreation and health and social work most likely to disagree that their traineeship made their transition from school to work easier (33% for both sectors (i.e. 38 out of 115 and 63 out of 191 respectively)). Trainee respondents from the Financial and Insurance and Information and Communication sectors were most likely to agree with this statement (96 out of 134 (72%) and 95 out of 134 (71%). These findings are mirrored when examining the actual outcomes of the traineeship following completion. Trainees in the Financial and Insurance sector were most likely to report that they had been offered a job after their traineeship (80 out of 134 respondents in the sector (60%)), followed by those in Construction (43 out of 76 (56%)). Trainees in education were most likely to report that they had not received an offer of a job after their traineeships (119 out of 172 (69%)), followed by those in health and social work (126 out of 191 (66%)) and arts and entertainment (74 out of 115 (64%)). Figure 6 - Trainee survey: job offers at the end of a traineeship, by sector Source: The 2022 trainee survey, 2023 study supporting this evaluation Inclusiveness Although inclusiveness is not a principle in the QFT, a large variety of stakeholders consulted in the 2023 study supporting this evaluation, including national authorities, the public employment services, youth organisations and the European Disability Forum, reported that vulnerable young people were less able to benefit from traineeships. For example, young people from rural areas and in the outermost regions, with disabilities, from a lower socio-economic background, with a migrant background, from the Roma community, or with lower educational attainment were identified as groups that may face obstacles in access, often linked to financial support. Young people from rural areas may often choose not to participate in traineeships in urban areas, as this would mean leaving their home regions without the guarantee of being hired afterwards. This suggests that additional support might be necessary for these groups. Companies were also reported to hire those trainees that are most skilled and/or educated, thus hampering access for young people with lower education level or skills. In addition, young people without networks (acquaintances, families, etc.) are likely to be less able to access traineeship opportunities, as traineeships are often found through such networks . Another barrier for vulnerable groups to access traineeships is the lack of traineeship programmes tailored to their needs, for example catering for specific training or upskilling needs or accessibility requirements in the case of disabilities. To overcome such obstacles, some Member States have introduced measures to help vulnerable young people access traineeships. The following box presents some such examples. Inclusive traineeships - Examples Latvia: ALMP traineeship providers in Latvia must provide an employment contract in accordance with the Labour Law. For a trainee with disabilities, the State provides support for making adjustments to the workplace up to €1,000. Ireland: A number of paid traineeships within the civil service are reserved for individuals from underrepresented groups, including those with a disability. Italy: In Italy, the maximum duration of a traineeship is 12 months. However, this is extended to 24 months for people with a disability to take into account the additional time they may need to get used to the workplace. Impacts on cross-border traineeships

The QFT (principle 16) recommends also that cross-border mobility of trainees in the European Union be facilitated inter alia by clarifying the national legal framework for traineeships and establishing clear rules on hosting trainees from, and the sending of trainees to, other Member States and by reducing administrative formalities. Principle 17 of the QFT recommends examining the possibility to make use of the extended EURES network (and to exchange information on paid traineeships through the EURES portal). Though cross-border traineeships seem to have increased over the years (363 out of 1,912 (19%) of the 2022 trainee survey respondents had undertaken a cross-border traineeship), barriers remain. These barriers are linked to the lack of (financial) resources and information. In the trainee survey: ·478 out of 1,293 (37%) indicated that a lack of financial resources limits their possibilities to undertake a traineeship abroad; ·478 out of 1,293 (37%) also mentioned a lack of interest as their main reason for not looking for a cross-border traineeship, which might indicate a broader need to further disseminate information on traineeships and their positive effects on young people’s career pathways; ·349 out of 1,293 (27%) of trainees surveyed mentioned not being well-informed about cross-border traineeships. The trainee survey indicated that 239 out of 1,836 (13%) of respondents made use of the EURES portal to find cross-border traineeship opportunities. The study supporting the Commission’s ex-post evaluation of EURES indeed highlighted difficulties in providing specific support services targeting youth regarding inter alia traineeships, mostly due to persisting differences in and a lack of harmonisation of national legislative frameworks for traineeships outside of education (e.g. legislative uncertainties regarding the definition of trainees). Efficiency It is difficult to provide quantitative estimations of the costs and benefits of the application of the QFT principles, even more so as it proved challenging to disentangle the benefits and costs related to providing traineeships in general from any additional or different benefits or costs related to the application of the QFT principles specifically. The analysis on costs and benefits is based on stakeholder consultations, the trainee survey and case studies that were carried out as part of the 2023 study supporting this evaluation . While evidence on quantifiable benefits is challenging to obtain, the study provides qualitative evidence of a range of benefits of quality traineeships for young people, employers and society. Benefits for young people Benefits of the QFT for young people include: an increased number and increased quality of traineeships, reduced levels of exploitation of trainees including a better understanding of their rights, and an increased level of validation and certification of learning outcomes. National interviewees from Estonia, Cyprus, Ireland, Luxembourg, Poland and Slovakia noted that the QFT can be linked to reduced exploitation of trainees, by highlighting the importance of traineeships having a written contract/agreement. National consultees from Malta and Luxembourg stated that the obligation to have such contracts/agreements in place has helped trainees understand their rights. National stakeholders from Croatia noted that ALMP traineeships designed to meet the QFT have improved trainee rights, putting them on the same level as other employees. According to 1,338 out of 1,836 (62%) respondents to the trainee survey, traineeships also facilitate young people’s transition to the labour market. Cypriot national authorities noted that QFT implementation had a positive impact on the results of ALMP traineeships, with 77% of trainees in the personal care sector in 2017-2018 employed in that sector after their traineeships. The trainee survey also highlighted key traineeship benefits such as trainees meeting their learning objectives and gaining skills. This is illustrated by 1,432 out of 1,836 (78%) respondents agreeing or strongly agreeing that their traineeship helped them achieve their learning and training objectives, and 1,506 out of 1,836 (82%) agreeing or strongly agreeing that they gained practical experience and relevant skills. Irish national stakeholders reported benefits for young people through improved skills, noting that the QFT helped highlight how their traineeship offer could be improved to align with best practice. A Career Traineeships pilot based on QFT principles was developed, and an evaluation of the pilot found that trainees enhanced their knowledge, skills, and proficiency in real work settings. Benefits for employers Based on the interviews carried out by the national experts with national stakeholders in the context of the targeted consultations , benefits for employers include an increased understanding of the quality aspects of a traineeship and more transparency about traineeship requirements, including the rights and obligations of employers. These allow for improving the quality of traineeships which, in turn, can improve the employer’s reputation and capacity to attract better candidates. Quality traineeships also enable employers to benefit from financial incentives that are available, such as in the case of ALMP traineeships, to fill skills gaps in their companies by attracting new talent that they can train for their individual/specific future skills needs, and to improve productivity and reduce turnover by investing in these individuals’ professional development and career progression. Furthermore, quality traineeships allow employers to ‘try out’ workers. Consultees from Finland and Malta noted that the QFT benefits employers through making traineeship requirements transparent. In particular the requirement to have a contract in place benefits employers as it clarifies their rights and obligations. Benefits for the society and the economy The QFT has supported youth employment in the EU by providing a more stable EU-wide quality framework for easing the school-to-work transition via traineeships, by giving young people job-based skills and a chance to demonstrate their potential to employers. In the Irish case study it was reported that “[b]enefits for society include increased employability as a result of the production of relevant skills tailored to employment needs” . However, it should also be noted that national authorities stressed the difficulty of assessing social impact, due to the problem of isolating the specific effect of the QFT on traineeships . Costs The 2023 study supporting this evaluation has also examined the costs associated with the implementation of the QFT. Costs identified for employers include concluding agreements with public employment services or training centres, supervising the trainees, assessing and certifying the trainees’ skills, advertising the traineeship opportunities, and developing training plans. These costs are difficult to quantify and breaking them down to costs associated with offering traineeships in general versus costs associated with implementing the QFT as such proved to be impossible. Nevertheless, the following (qualitative) analysis describes administrative and adjustment costs linked to traineeships in general and provides indications, where possible, as to which costs may be attributed to the QFT.

Administrative costs for implementing OMTs and ALMP traineeships differ, with ALMP traineeships offering many more forms of financial support for employers, while entailing also administrative costs both for employers and for public authorities. Additional costs for public authorities include investing in public services and labour inspectorates to monitor compliance with national legislation. Applying for and managing subsidies is itself costly to employers, especially for small companies with limited capacity for these administrative tasks. In the Irish case study , for example, stakeholders emphasised the significance of administrative costs for employers due to higher levels of quality assurance and compliance with contractual frameworks for ALMP traineeships. However, none of these costs can be directly attributed to the QFT. Adjustment costs in adapting to the requirements of QFT principles were also noted by some of the consulted stakeholders, including: the costs associated with designing programmes, implementing new legislation, assessing trainees’ skills at the start of a traineeship, developing training plans to ensure learning objectives are met, supervising trainees, and certifying trainees’ skills at the end of a traineeship. In general, costs were raised as a limiting factor for applying the QFT principles. National authorities and employers mentioned limited human and financial resources (mainly linked to the need to provide supervisors, specify learning objectives and cooperate with the public employment services in case of ALMP type of traineeships) as an obstacle. National authorities also referred to their limited resources for the promotion and communication about traineeships. No evidence was found of significant enforcement costs associated with the implementation of the QFT and stakeholders did not identify such costs in the interviews or case studies. The key issue here is that enforcement of traineeship regulations would normally be undertaken by the national labour inspectorate or equivalent and any costs would be incurred by the relevant national authorities. Such inspections, however, normally focus on the enforcement of the relevant national legislation. Even where that legislation has been influenced to some extent by the QFT it is not possible to separately identify enforcement costs due to the QFT. 16 Member States use financial incentives to support quality improvements in traineeships. They are generally used in three main ways: to encourage or enable traineeships; to improve their quality; and/or to enable trainees to be kept on at the end of their traineeship. Financial incentives are mainly used in the case of ALMP traineeships. Table 6 - Financial incentives in Member States Type of incentive Member State To encourage or enable traineeships BG, CY, DE, EL, ES, HR, IT, LU, LV, MT, SK, SI, EL, PL, RO To improve traineeship quality BG To enable trainees to be hired following their traineeship BG, SK, IE, ES These types of incentives include public subsidies and/or social security contribution reductions for companies providing traineeships. Member States have also relied on financial support from European Structural and Investment Funds, such as the Youth Employment Initiative and the European Social Fund (ESF), as recommended by the QFT (principle 18). In targeted consultations , public employment service representatives highlighted that employers can receive grants to support wages for mentors and supervisors. A national trade union noted that ESF funding is also used by employers, but requires a great deal of administrative commitment in terms of reporting. Examples of financial incentives and use of European funds Spain The case study on Spain gives the example of subsidies to employers for ALMP traineeships funded through the Youth Guarantee in November 2020. The subsidies ranged from €694.82 to €810.62 per month per trainee, equal to 1.2 to 1.4 times the IPREM (with the higher rate applying to trainees with disabilities). Subsidised employers must pay a wage equal to 80% of the IPREM and social security contributions and must justify the training content of their traineeships. The implication is that the difference between the wage and the subsidy (i.e. 40-60% of the IPREM) covers the extra cost of providing the traineeship. Bulgaria The New Opportunity for Youth Employment initiative offers employers incentives to hire young people up to the age of 29, and subsidises the cost of a supervisor, transport costs and wages for trainees. This initiative also includes an exemption from a number of social security contributions if the employer subsequently signs a permanent contract with the trainee. Germany

Employers who take on young people for in-company introductory training receive a subsidy that covers trainees’ pay and a lump sum for the trainees’ total social insurance contributions. Based on the case studies and targeted consultations conducted in the 2023 study supporting this evaluation , the most often held perception of stakeholders is that the total costs related to the implementation of the QFT are proportionate to the benefits. Throughout the research , stakeholders highlighted benefits more often than costs, and while quantification was difficult, their inability to identify significant costs associated with the QFT in its current form suggests that such costs are unlikely to be large enough to outweigh the benefits that were more frequently identified. Among the factors limiting the efficiency of the QFT are a lack of monitoring and enforcement and a lack of awareness. In particular, some employers do not seem to be aware of the potential benefits of offering a quality traineeship, nor of funding opportunities available to support employers offering such traineeships. In targeted consultations , employer representatives in particular emphasised that the implementation of the QFT principles is also likely to be less efficient in small companies and micro-enterprises than in larger firms. Coherence with other policies supporting quality jobs for young people At EU level, the objectives, target groups and measures to implement the QFT display overall a good level of coherence with other relevant EU initiatives, policies as well as funds and programmes. The QFT contributes to the European Pillar of Social Rights, in particular principle 4 on ‘Active support to employment’ and the objectives of the EU Youth Strategy , in particular goal 7 ‘Quality Employment for All’, which, amongst others, calls for the recognition and validation of competencies acquired through internships, apprenticeships and other forms of work-based learning, volunteering and non-formal education as well as equal access to quality information and adequate support mechanisms to prepare young people for the changing labour market and future of work. In addition, the QFT is coherent with the Reinforced Youth Guarantee , which aims to ensure that all young people receive a good quality offer of employment, continued education, an apprenticeship or a traineeship within four months of becoming unemployed or leaving formal education and recommends to ensure that traineeship offers adhere to the minimum standards laid out in the QFT. Coherence with the European Solidarity Corps is found in the projects funded and supported under this initative, amongst which traineeships. Synergies also exist with other EU initiatives on traineeships and apprenticeships, such as the Digital Opportunity Traineeships funded under Erasmus+, which aims to help companies fill vacancies with digitally competent candidates through traineeships. and the European Framework for Quality and Effective Apprenticeships (EFQEA) that sets out similar quality principles for apprenticeships (more details below). It is also coherent with the goals of the main relevant EU funding mechanisms, including the Youth Employment Initiative (YEI), the ESF+, NextGenerationEU and Erasmus+. As for coherence with relevant EU labour legislation, the Directive on adequate minimum wages in the European Union applies to (paid) trainees insofar as they fall under the definition of ‘worker’, as defined by national law with consideration to the case-law of the Court of Justice of the European Union. The Council Recommendation on Access to social protection for workers and the self-employed similarly only addresses the situation of trainees who are in an employment relationship. Overall, there is also a fairly good level of coherence between the objectives, target groups and measures to implement the QFT, and the relevant employment, social, and education and training policies at national and regional level. These policies have the common goal to provide young people with relevant practical work experience and skills in a safe environment in which their rights are protected. The way various national or regional measures are implemented might however lead to varying degrees of coherence across Member States. Overall, the majority of national and regional stakeholders consulted in the 2023 study supporting this evaluation, including policymakers, social partners, youth organisations and chambers, were of the opinion that there was a better coherence of policies at EU level than at national level. These views often referred to the QFT not being fully integrated in national or regional policy, but only to a certain extent. In particular, the degree of coherence with the QFT is generally higher for employment policies, as compared to policies in the fields of education, training or social inclusion. This reflects the fact that the QFT excludes traineeships which are a mandatory part of formal education or training programmes, and that the responsibilities for labour market and education policies are often dispersed between different parts or levels of government. The 2023 study supporting this evaluation pointed out that due to the complexity of labour law and its interaction with education and training systems, there remain some grey areas in which there is potential for duplication and incoherence. This notably concerns the interaction of policies supporting traineeships with those supporting apprenticeships. In this regard, the European framework for quality and effective apprenticeships (EFQEA) of March 2018 sets out 14 criteria for quality and effective apprenticeships. There are many similarities with the QFT, for example addressing dimensions such as the written agreement, learning objectives or outcomess, transparency and working conditions, as well as EU-level monitoring and cooperation with other key stakeholders. Most stakeholders consulted under the 2023 study supporting this evaluation are of the opinion that the EFQEA has led to greater involvement of stakeholders, and has a clearer scope, a higher and more specific quality ambition in terms of more direct recommendations, a higher degree of regulation of apprenticeships, which are generally considered as employment contracts, and benefits from useful supporting measures under the European Alliance for Apprenticeships (EAfA) and the Apprenticeship Support Services. These perceptions are to be seen in light of fundamental differences between apprenticeships and traineeships, whereby apprenticeships are required to lead to a full qualification of professional or vocational education and training, while traineeships covered by the QFT are, at most, complimentary to education and training. In addition, apprenticeships are highly regulated, often on a tripartite basis, whereas traineeships (in particular the open market type) are either unregulated or partially regulated. There are also different degrees of coherence within the field of national employment policies. Policies on ALMP traineeships, which by nature are designed in the context of national employment integration measures, tend to be better aligned with the goals of the QFT. This is less so for policies regarding OMTs, due to the diversity of regulatory approaches to traineeships across the EU and the prominent role of employers in the determination of the conditions for these types of traineeships. Some national and regional stakeholders (including policymakers, business representatives, education and training organisations and social partners) suggested (during interviews and expert meetings held in the targeted consultations) a widening of the scope of the QFT to cover more types of traineeships, including traineeships which form a part of education and training programmes. However, at the validation workshop (September 2022) that took place in the context of the 2023 study supporting this evaluation, some employer organisations and national authorities raised concerns that broadening the scope of the QFT could give rise to discrepancies with existing legislation on compulsory traineeships and/or traineeships that are part of education and might further complicate ongoing discussions on issues such as remuneration. Finally, in some Member States (e.g. MT, RO, SK), national and EU funding has been a driver for promoting coherence with the QFT. National policymakers in Romania and Slovakia particularly underlined the role of the Youth Guarantee in ensuring the QFT principles were implemented. In Malta, youth organisations highlighted the role of national and EU funds (especially the ESF) in promoting synergies and coherence with the QFT, in particular by bringing national and regional policymakers from relevant fields (education and training, employment, social) together. 4.2. How did the QFT make a difference and to whom? Despite the challenges in isolating the impact of the QFT from the impact of pre-existing national measures and of traineeships in general, the 2023 study supporting this evaluation suggests that the QFT has added value to the design and implementation of policies on both OMTs and ALMP traineeships in several Member States. The added value was found to have been greatest to national and regional level policy-makers. In particular, the QFT has provided a common EU reference point for quality in traineeships, which has helped national authorities to align and improve national systems and legislation: ·In Bulgaria, interviewees stated that the QFT has specifically driven legislative changes regulating OMTs.

·In Spain, although legislation on traineeships was already in place, more recent legislative amendments are in line with the QFT, improving legislative and possibly also practical implementation. ·In Ireland too, it was reported that the QFT provided a framework for the development of the country’s own national policy on traineeships, and was of great benefit in terms of helping policymakers to do this quickly and effectively. ·In Greece, the QFT has been the impetus for a range of practical improvements to traineeships, such as putting into place a register of traineeship providers, a register of companies, and a code of ethics for traineeships. The extent of the EU added value varies according to factors such as whether instruments and measures were already in place prior to the QFT. The EU added value appears to have been greatest in Member States where traineeship systems were less developed before the adoption of the QFT. This is supported by views gathered in the targeted consultations with representatives from the newer Member States. Stakeholders from Croatia for example highlighted that the QFT helped to lay the groundwork and set policy standards that had an extra weight in the national context. In Romania, recent legislation on traineeships was modelled on all the principles listed in the QFT. In Bulgaria, stakeholders emphasised that, since 2014, traineeships offered by large multinational companies have become more structured, including an individual traineeship plan and a mentor. National authorities (such as ministries of labour and education and public employment services) all agree on the added value of the QFT in setting out a common EU framework as well as its impact on the ground. Youth, civil society and trade unions generally agree too, but they also consider that the EU added value is somewhat limited by the weaker application of the QFT on the ground. As for employer organisations, the added value lies in an increased understanding of the quality elements of traineeships, and in case the QFT principles are applied, reputational benefits. Some employers are of the opinion that the QFT has limited added value because labour markets vary substantially across Member States, while others highlight that the QFT’s added value precisely lies in its flexible and non-binding nature. 4.3. Is the QFT still relevant? The principles of the QFT remain relevant for improving the quality of traineeships and fostering the labour market integration of young people. Relying particularly on the public consultation survey, the targeted consultations (in particular the interviews by national experts with national stakeholders and the trainee survey), and the case studies carried out in the 2023 study supporting this evaluation, stakeholders agree that while most QFT principles are pertinent, the following elements from the QFT tend to be particularly associated with better post-traineeship outcomes: learning objectives, written agreement and the provision of a supervisor. There were more divergent views on the relevance of limiting the duration of traineeships. On the one hand, a limited duration can prevent the replacement of regular jobs by traineeships. On the other hand, sufficiently long traineeships can allow employers to see them as an investment in their future workforce and enable young people to acquire relevant competences. As for the relevance of the QFT itself, there are mixed views on whether the QFT should be revised, remain in place or even be discontinued. While a few stakeholders (from different stakeholder groups in BE, EL, FI, IE, IT, LT, LV, PT, RO) consider that the impact of a discontinuation would be limited given the level of integration of QFT principles in their national legislation, other stakeholders (also from various stakeholder groups in AT, BG, DE, EL, IT, MT, PL) have underlined the importance of the existence of a common policy guidance at EU level which continues to give an impetus for the development of national policies on traineeships. Employer organisations and national authorities generally called for retaining the QFT in its current form, while introducing flanking measures to support a better implementation on the ground, such as greater awareness raising and mutual learning, robust and comparable data on traineeships across the EU, more quantitative monitoring of implementation and a better coordination amongst different actors. The potential added value of such measures was also highlighted in the European Parliamentary Research Service (EPRS) study. Trade unions and youth organisations, however, call for a more significant alteration of the nature and content of the QFT, notably by making its implementation binding, expanding its scope and adding additional quality elements. The 2023 study supporting this evaluation shows that the non-binding nature of the QFT has made it possible to take into account the diversity of national education and training and labour market environments and strike a balance between the need to ensure minimum standards and preserve a degree of flexibility – a view largely supported by national authorities and employer organisations. At the same time, it has also allowed different regulatory approaches at the national level to continue, resulting e.g. in different levels of quality standards for traineeships, as highlighted by trade unions. National employer organisations highlight that having a set of binding principles that are applicable to all Member States would not be appropriate for fostering the stable labour market integration of young people because of the important diversity in national regulation on traineeships, in labour law and in the degree of social partner involvement in defining traineeship standards. Employer organisations and trade unions (AT, DE, DK, FI) point out that the relevance of the QFT also depends on the level of general social protection and labour standards applied in individual Member States. In Member States where these standards are generally high (such as AT, DE, DK, FI), the QFT is considered less relevant. Against this background, the flexibility and adaptability of the QFT in function of varying labour market needs were considered important. In addition, national authorities, employer organisations, education and training organisations and trade unions considered that the scope of the QFT, limited to OMTs and ALMP traineeships, was a factor reducing its relevance for fostering stable labour market integration. Extending the scope to traineeships which are part of formal education or training programmes, could increase the relevance of the framework, as such traineeships also aim to increase young people’s employability. The 2023 study supporting this evaluation also indicated quality principles which are considered to be missing from the QFT. Stakeholders from youth organisations as well as trade union representatives and some national authorities highlighted that the QFT currently does not sufficiently take into account that youth is not a homogeneous group. As a result, the QFT may thus be less relevant in addressing the specific needs of young people and to the broader Union aim of social cohesion and inclusion. Therefore, a possible additional quality element could concern ensuring a greater recognition of the diversity of situations of young people, in particular when it comes to the outreach to and accessibility of traineeship opportunities for vulnerable groups. Remuneration has the potential to increase the quality of traineeships, which has been demonstrated also by previous research. For example, a study done by the International Labour Organization illustrates the tendency of remunerated traineeships to be more structured and formalised, thereby increasing the likelihood that young trainees gain relevant skills and competences. While trade unions, youth and civil society organisations as well as EU and international agencies consider remuneration an important aspect, not all employers consider it as an element increasing the quality of traineeships. Some employers argue that there are also negative consequences of remuneration, such as additional costs for the employer and a reduced numbers of traineeship offers, but also a lack of clarity on the legal status of trainees. The current QFT only recommends transparency on whether an allowance or compensation is applicable, and if applicable, its amount. In the trainee survey, 220 out of 449 (49%) of the trainee survey respondents would like to find information in the vacancy notice about entitlement to compensation or allowance and 193 of 449 (43%) information about its amount. As for being paid (not a QFT principle), 1,597 of 1,836 (87%) of trainees surveyed reported that being paid for their traineeship was essential or important for them. 1,542 of 1,836 (84%) of trainees surveyed reported that being paid at least the minimum wage was important or essential. Remuneration is an incentive for trainees to remain in and complete a traineeship, and could contribute to guaranteeing equal access to traineeships and to the labour market. However, legislation on remuneration, if set at a low level, may prolong the labour market transition for young people and drive labour standards down. For example, in Croatia, a 2018 evaluation of a traineeship scheme found that the low wages of trainees in the scheme increased the probability of inactivity, and thus delayed their entry into the labour market. The reason for this has been linked to low wages of trainees (at the time between 29% and 43% of the average net wage) which disincentivised young people from taking part in the programme. The impact on wage standards was also noted, with stakeholders highlighting that the scheme lowered labour costs of young people and other workers. This potential adverse effect was also underlined in the case study on Italy, in which interviewed stakeholders expressed concerns about the COVID-19 crisis resulting in a further increase in the number of traineeships (as opposed to entry level jobs). These stakeholders cautioned that an increased use of unpaid or low-paid traineeships might have a negative effect on entry-level wages for youth.

Young people’s access to social protection varies between Member States, and the entitlements for trainees are not always clear. Research highlights that, currently, in the context of OMTs, employers do not have an obligation to contribute to social security for trainees in 10 out of 27 Member States. For the remaining 17 Member States, social security coverage is either at the same level as any employee or only includes specific types of coverage. Against this background, many stakeholders, in particular youth and civil society organisations, consider that guaranteeing trainees’ access to social protection coverage would increase the relevance of the QFT. The trainee survey highlighted in particular the importance of the following aspects of social security: ­access to benefits related to accidents at work and occupational diseases (3,295 out of 3,787 (87%) of trainee respondents considered this essential or important) ­being covered by health and sickness benefits (3,181 out of 3,787 (84%) of respondents); ­having access to paid sick leave (2,991 out of 3,787 (79%) of respondents); ­access to minimum income support ((2,954 out of 3,787 (78%) of respondents); ­accumulating pension rights (2,613 out of 3,787 (69%) of respondents); ­having access to unemployment benefits (2,535 out of 3,787 (67%) of respondents). The public consultation carried out by the Commission confirmed these views. Although the COVID-19 pandemic encouraged innovative approaches to traineeship supply and delivery, it has evidenced young people’s vulnerability to crises. It has moreover highlighted that the QFT might not sufficiently address changes in the labour market, including the increasing role of remote working and digital skills. Provisions on telework and online guidance are currently not included in the QFT and could increase its relevance. Traineeships can be an opportunity for employers to address increasing skills mismatches due to megatrends, such as the digital transformation of the economy. Some employer organisations have suggested an increased focus on the learning component of traineeships. They notably argued that a mapping of traineeship providers’ skills needs and an assessment of trainees’ competences before and after their traineeships could strengthen the learning element in traineeships. As regards the acquisition of relevant skills, trainees themselves emphasised the importance of access to training activities during their traineeship. Another important element is the provision of adequate mentorship, even more so in the context of digital traineeships . However, some employer representatives and national authorities warn about additional costs, especially for SMEs . Consultations with EU and national stakeholders (in interviews as part of the targeted consultations) gave indications that the QFT may be lacking practical guidance for employers / traineeship providers on the overall implementation of the QFT. Conditions for employers to receive financial support for traineeships, for example by establishing trainee quotas, or by ensuring that the provision of EU and national funding and/or tax exemptions is subject to conformity with the QFT principles could, according to EU and national stakeholders consulted, strengthen the relevance of the QFT. Finally, the QFT could also encourage companies to employ trainees after the traineeship, or help them find a job after the traineeship (i.e. post-placement support). 5. Conclusions and lessons learned 5.1 Conclusions Traineeships continue to be an important pathway for young people to enter the labour market, whilst learning “on the job”. Quality traineeships, which reflect the principles of the QFT, contribute to increasing young people’s employability in terms of their skills and their access to professional networks, as highlighted in particular by the views of trainees through the trainee survey. Quality traineeships also bring distinct opportunities and benefits for employers to attract, train and retain young talent. This is particularly relevant in the context of the pronounced skills mismatches and skills shortages, which especially affect some sectors in the EU labour markets. It needs to be reiterated that a key challenge in assessing the impact of traineeships and the QFT relates to the lack of systematic data collection at EU level and in Member States. Moreover, it is difficult to disentangle the impact the QFT may have had on the quality of traineeships and on youth employment from the impact of other factors (such as the economic situation, national contexts, existing national legislation and/or policies). In terms of effectiveness, the provisions of the QFT that are perceived as most impactful on young people’s labour market integration seem to be those outlining the need to determine the learning and educational objectives of the traineeship and the written agreement. The QFT provided added value as a reference point at EU level for Member States’ regulatory action on the quality of traineeships, in particular in Member States with less developed traineeship systems, where it helped to foster policy and legislative changes at national level. Since 2014, 14 Member States introduced legislative changes to cover traineeships, which in some cases may be linked to the existence of the QFT though the analysis does not allow to establish a systematic causal link given that it is a non-binding instrument. The prevalence of specific legislative provisions as well as their conformity with the principles of the QFT were found to be higher for ALMP traineeships than for OMTs. Overall, a slight improvement in terms of conformity can be observed for OMTs with four Member States fully/mostly aligned in 2016 versus seven Member States in 2021. A larger improvement is observed for ALMP traineeships, with 18 Member States fully/mostly in conformity in 2021 versus 15 in 2016. In addition, irrespective of the degree of implementation of the QFT principles in national legislation, there is a general room for improvement when it comes to the application of the QFT principles on the ground, as well as their monitoring and enforcement. As for the QFT facilitating the cross-border mobility of trainees in the EU, there are indications that the number of transnational traineeships has increased, but young people still face difficulties due to a lack of financial means and the unavailability of relevant and sufficient information.

The evaluation lacked quantitative evidence on costs and benefits. Based on the views expressed by the consulted stakeholders, the costs appear to be low, while the benefits are considered relatively high. Overall, the cost for employers related to the implementation of the QFT is generally perceived as proportionate to the benefits, such as a better understanding of the determinants of traineeship quality, reputational advantages, an increased attractiveness to young talent, and a more affordable way to invest in potential future workers. However, the implementation of the QFT can be less cost effective for small and micro enterprises than for larger firms. Financial incentives, such as those supporting job offers after the completion of a traineeship, can help increase the benefits to traineeship providers compared to the costs involved. Benefits of the QFT for trainees include improved working conditions, as well as better training and learning content, which increase their chances of entering stable employment. The QFT was found to be coherent with the objectives and actions of other EU level initiatives, strategies, programmes and funding instruments. As for coher