COMMISSION STAFF WORKING DOCUMENT Analytical document Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Towards a Quality Framework on Traineeships Second-stage consultation of the social partners at European level under Article 154 TFEU
Date: 2012-12-05
Institutions: European Commission
Subjects: Internet site, access to a profession, job access, job creation, labour mobility, quality standard, traineeship, youth unemployment

EUROPEAN 
COMMISSION 

Brussels, 5.12.2012  
SWD(2012) 407 final 

COMMISSION STAFF WORKING DOCUMENT 

Analytical document 

Accompanying the document 

COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN 
PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL 
COMMITTEE AND THE COMMITTEE OF THE REGIONS 

Towards a Quality Framework on Traineeships 

Second-stage consultation of the social partners at European level 
under Article 154 TFEU 

{COM(2012) 728 final} 
{SWD(2012) 408 final} 

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COMMISSION STAFF WORKING DOCUMENT 

Analytical document 

Accompanying the document 

COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN 
PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL 
COMMITTEE AND THE COMMITTEE OF THE REGIONS 

Towards a Quality Framework on Traineeships 

Second-stage consultation of the social partners at European level 
under Article 154 TFEU 

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TABLE OF CONTENTS 

Introduction .................................................................................................................. 4 

Types of traineeships, their benefits and their costs .................................................... 6 

Definition of traineeships............................................................................................. 6 

Types of traineeships and their regulation ................................................................... 7 

Benefits and costs of traineeships ................................................................................ 9 

Consultations and stakeholders views........................................................................ 13 

Problem Definition..................................................................................................... 15 

Nature and extent of problems ................................................................................... 15 

Number and share of low quality traineeships........................................................... 21 

Problem drivers and trade-offs: The role of market failure ....................................... 23 

Quality issues and transnational traineeships............................................................. 26 

Legal basis and subsidiarity ....................................................................................... 28 

Policy Objectives ....................................................................................................... 30 

Policy coherence – contribution to Europe 2020 ....................................................... 31 

Possible avenues for EU action.................................................................................. 31 

No initiative at EU level (baseline scenario).............................................................. 33 

Creation of an information website............................................................................ 34 

Quality label for traineeships ..................................................................................... 35 

European Quality Framework for Traineeships......................................................... 36 

Combination of options.............................................................................................. 39 

Final overview............................................................................................................ 39 

References .................................................................................................................. 40 

1. 

2. 

2.1. 

2.2. 

2.3. 

3. 

4. 

4.1. 

4.2. 

4.3. 

4.4. 

5. 

6. 

7. 

8. 

8.1. 

8.2. 

8.3. 

8.4. 

8.5. 

8.6. 

9. 

ANNEXES ............................................................................................................................... 43 

Annex I – Apprenticeships vs. Traineeships............................................................................ 43 

Annex II – Traineeship study, Executive summary ................................................................. 44 

Annex III – Regulatory Framework ......................................................................................... 48 

Annex IV – A voluntary approach to Quality Labels for Traineeships ................................... 49 

Annex V – Sectoral distribution of traineeships by country .................................................... 50 

Annex VI - Market failure in traineeships ............................................................................... 51 

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ANNEX VII – Comparison of the quality elements considered by the Commission with the 

Code of Best Practice (UK), the Loi Cherpion (FR) and the European Quality 
Charter on Internships and Apprenticeships presented by European NGOs ............. 54 

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1. 

INTRODUCTION 

Social Partners consultation 

According  to  Article  154  TFEU  Social  Partners  have  to  be  formally  consulted,  before  the 
Commission submits proposals in the social policy field (e.g. working environment, working 
conditions,  social  security  and  social  protection  of  workers,  and  the  integration  of  those 
excluded from the labour market and the combating of social exclusion, Article 153 TFEU). 

Social partners are consulted in two stages – first on the direction of Union action and later on 
the  content  of  the  envisaged  proposal.  This  document  presents  background  information  to 
support  the  second  stage  consultation  of  the  European  social  partners  on  a  possible  EU 
initiative on a Quality Framework for Traineeships.  

The first stage consultation was closed on 23 October 2012. It followed a public consultation 
carried out between 19 April and 11 July 20121.  

This  second  stage  consultation  will  gather  opinions  of  the  European  social  partners  on  the 
content of the envisaged proposal. The possible outcomes of this procedure are the following: 
social partners can enter into negotiations (which may last max. 9 months), and may reach an 
autonomous  agreement  or  may  ask  the  Commission  to  make  a  legislative  proposal 
implementing  their  agreement. If social partners fail to agree or decide not to negotiate, the 
Commission has to assess the situation and can present its own proposal.  

Context  

Currently over five million young people in the EU under the age of 25 cannot find a job, and 
in  a  large  number  of  Member  States  transitions  from  education  to  work  have  become 
increasingly  longer,  more  unstable  and  uncertain.  In  this  context,  increasing  the  access  of 
young  people  to  the  labour  market  is  a  top  priority  for  policy  makers  and  facilitating  the 
transition  from  education  to  work  is  key  in  this  context.  By  providing  a  possible  stepping 
stone  to  more  productive  employment  careers,  traineeships  can  help  foster  sustainable  job 
creation, reduce youth unemployment and eventually contribute to raise the employment rate 
–one of the headline targets of the Europe 2020 Strategy.  

Despite the benefits of traineeships, concerns about their effectiveness and quality have been 
recognized by European Institutions. In its 2010 Resolution2 the European Parliament called 
specifically  for  better  and  secured  internships;  for  a  European  Quality  Charter  setting  out 
minimum standards for internships to ensure  their  educational value  and avoid exploitation; 
and  for  young  people  to  be  protected  from  those  employers  who  are  "exploiting  the 
willingness of young people to learn without any future prospect of becoming fully established 
as  part  of  their  workforce."  In  2011,  the  European  Commission  foresaw  in  its  Youth 
Opportunity Initiative the launch of a Quality Framework on Traineeships by the end of 2012.  

In its conclusions on promoting youth employment of June 2011, the Council acknowledged 
that  "given  a  lack  of  appropriate  employment  opportunities,  in  some  Member  States  a 
significant  number  of  young  people  have  no  other  choice  but  to  take  up  precarious 
employment  offers,  such  as  unpaid  or  low-paid  internships  (…)."  In  response,  it  asked 

1 
2 

SWD(2012)99, 18.04.2012. For more details see section 3 
EP 2009/2221(INI), 06.07.2010 

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Member  States  to  "tackle  labour  market  segmentation  where  appropriate  by  developing 
adequate contractual arrangements, strengthening activation measures as well as promoting 
sustainable and high quality employment, securing decent working conditions and providing 
adequate income protection with clear incentives for young people, while respecting national 
needs and starting positions and the important  role  of  the social partners" and to "promote 
quality mobility for young people at both national and EU level." Similarly, in May 2011 the 
Council  Conclusions  on  the  structured  dialogue  with  young  people  on  youth  employment 
emphasized that "(…) a quality framework for internships is desirable in order to guarantee 
the  educational  value  (…)"  of  traineeships3.  Furthermore,  the  June  2012  European  Council 
concluded  that  "It  is  crucial  to  address  youth  unemployment,  in  particular  through  the 
Commission's  initiatives  on  youth  guarantees  and  the  quality  framework  for  traineeships 
(…)". 

Member  States,  too,  have  been  actively  examining  traineeships  in  order  to  improve  their 
functioning.  This  has  led  to  a  series  of  initiatives,  typically  aiming  at  increasing  safeguards 
against trainee exploitation and addressing quality concerns (see Box 1). 

Box 1. Examples of Member States’ Efforts to Enhance Trainee Protection in the Open 

Market 

■ Austria: in an effort to help the so-called ‘internship generation’ secure regular employment 
instead  of  successive  traineeships,  the  2010  Aktion  +  6000  Programme  provides  wage 
subsidies to employers if, upon completion of the traineeship, they keep on the trainees. 

■ France: in an attempt to address the issue of successive traineeships, the 2011 Loi Cherpion 
stipulates  that,  inter  alia,  companies  should  wait  for  a  period  corresponding  to  1/3  of  the 
length of the previous traineeship before taking on a new trainee in the same role. This law 
strengthens the legal framework of traineeships and reinforces the trainee’s rights, terms and 
conditions, including trainee compensation. 

■ Greece: in order to prevent employers from replacing regular staff with trainees, the 2010 
Work  Experience  Programme  for  New  Labour  Market  Entrants  stipulates  that  companies 
which have reduced their staff in the last six months are not eligible to take part. In addition, 
an employer cannot renew the traineeship contract with the same trainee. 

■ UK: a number of voluntary charters (CIPD’s Internship Charter) and codes of best practice 
(Code  of  Best  Practice  for  Quality  Internships)  are  promoted  in  an  effort  to  improve  the 
quality of traineeships in the open market. 

Source: Traineeship study, European Commission (2012a), p. 65 

The  European  cross-sectoral  social  partners  (BusinessEurope,  UEAPME,  CEEP,  ETUC) 
agreed  to  "promote  more  and  better  apprenticeship  and  traineeship  contracts"  and  "ensure 
the right working conditions to welcome and support new entrants in the enterprise" as key 
actions  under  their  2010  Framework  Agreement  on  Inclusive  Labour  Markets.  In  their  joint 
work programme 2012-2014,4
 the European social partners - aware of the remits of European 
competences in the field of employment and social affairs – agree on the need in general to 

3 
4 

8664/11 JEUN 19 SOC 313 
See e.g. www.ueapme.com/IMG/pdf/EUSD_work_prog_2012-2014.pdf. 

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“establish the appropriate framework conditions to ensure employment opportunities for all 
workers and to allow for the integration, retention and development of workers in European 
labour markets”; and more specifically to take action to remedy the “unacceptable situation” 
of youth unemployment; to assess the situation of young people as a priority; and to “focus on 
the link between education, young people’s expectations and labour market needs, taking into 
account young people’s transition into the labour market, in an effort to increase employment 
rates  in  general.”  While  noting  that they  are  put  to  a  test  in  this  exceptional  situation,  with 
success measured in their capacity to put forward solutions to EU labour markets problems, 
the European social partners announce that they “will make, in the context of a framework of 
actions, concrete recommendations also to Member States and the EU institutions [and] also 
contribute to the G20 agenda on youth employment.” Finally, they also agree to jointly ensure 
better impact and/or implementation of EU social dialogue instruments throughout Europe. 

To  ensure  the  respect  of  the  principle  of  the  autonomy  of  the  social  partners  this  document 
addresses  issues  such  as  types  of  traineeships,  benefits  and  costs,  the  results  of  stakeholder 
consultations, the definition of the problem, the subsidiarity check, the policy objectives and 
reflections on how an EU initiative could achieve them. It does not claim to present a detailed 
assessment of policy options and their potential impacts – all of which would be addressed in 
a  possible  future  impact  assessment,  taking  due  account  of  the  outcomes  of  the  2nd  stage 
social  partner  consultation.  It  does  include,  however,  evidence  and  first  indications  on  the 
costs and benefits of policy options and their potential impacts where available. It further lays 
out possible future steps to support a more detailed analysis in the context of a possible future 
full impact assessment. 

2. 

TYPES OF TRAINEESHIPS, THEIR BENEFITS AND THEIR COSTS 

2.1. 

Definition of traineeships 

Traineeships, also known as internships or stages, are understood as a limited period of work 
practice  spent  at  business,  public  bodies  or  non-profit  institutions  by  students  or  by  young 
people  having  recently  completed  their  education,  in  order  to  gain  some  valuable  hands-on 
work  experience  ahead  of  taking  up  regular  employment.  Given  their  similar  aims, 
traineeships  are  often  confused  with  apprenticeships;  however,  even  though  the  distinction 
between the two can be fuzzy in some cases, traineeships and apprenticeships differ in several 
respects: 

•  An apprenticeship in a strict sense is a systematic, long-term training alternating periods at 
the  workplace  and  in  an  educational  institution  or  training  centre.  The  characteristics  of 
the apprenticeship (e.g. occupation, duration, skills to be acquired, wage or allowance) are 
defined  in  a  training  contract  or  formal  agreement  between  the  apprentice  and  the 
employer  directly  or  via  the  education  institution.  Apprenticeships  are  normally  part  of 
formal  education  and  training  at  upper  secondary  level  (ISCED  3),  the  duration  of  the 
training  is  on  average  3  years,  and  a  successful  completion  leads  to  a  nationally 
recognised  qualification  in  a  specific  occupation.  However,  most  initial  vocational 
training  programmes  include  some  optional  or  compulsory  practical  training  either  in 
school  or  in  a  company  and  the  borders  between  apprenticeships  and  school-based 
schemes which include traineeship periods at a workplace are not clear-cut. 

•  Traineeships  on  the  other  hand  can  be  described  as  work  practice  including  a  training 
component.  They  allow  to  document  practical  work  experience  as  part  of  the  individual 
CV and/or as requested in educational curricula or to gain work practice for the purpose of 

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facilitating  the  transition  from  education  and  training  to  the  labour  market.  They  are 
predominantly short- to middle-term (a few weeks up to 6 months, in certain cases 1 year).  
•  Traineeships within education can be an optional or mandatory part of the curriculum or 
of  the  graduation  procedure.  Traineeships  can  be  part  of  labour  market  programmes 
aiming at connecting or reintegrating people with the labour market.  
In most Member States, traineeships and related rights and conditions are only regulated 
in a fairly general way at best and may not be regulated at all. In a majority of Member 
States, a traineeship contract in particular explicitly is not an employment contract.  

• 

This  document  deals  with  traineeships  only.  For  greater  details  on  the  distinction  between 
traineeships and apprenticeships, please see Annex I. 

2.2. 

Types of traineeships and their regulation 

One may distinguish five major – partly overlapping - types of traineeships:5  

1.  Traineeships  forming  an  optional  or  compulsory  part  of  academic  and/or  vocational 

curricula (i.e. traineeships during education); 

2.  Traineeships  which  form  part  of  mandatory  professional  training  (e.g.  law,  medicine, 

teaching, architecture, accounting, etc.); 

3.  Traineeships as part of active labour market policies; 
4.  Traineeships on the open market, generally after completion of studies and/or as part of 

job search; 

5.  Transnational traineeships. 

Type  1  and  2  traineeships  are  linked  to  educational  and  training  programmes  and  curricula 
and are often a precondition for diploma or licences to practice. Educational institutions are 
generally involved in their organisation and monitoring. Similarly,  employment  services  are 
involved  in  the  organisation  of  type  3  traineeships.  Generally,  the  most  tightly  regulated 
traineeships relate to the case of specific professions whose exercise requires the completion 
of compulsory traineeships as part of mandatory professional training by relevant bodies and 
professional  associations.  In  almost  all  Member  States,  the  most  regulated  professions  with 
long  periods  of  traineeships  are  those  related  to  health  (medicine,  nursing,  pharmacy, 
dentistry, psychology, psychotherapy, veterinary medicine etc.) and law (lawyers, barristers, 
judges); compulsory traineeships are also associated with some technical occupations such as 
architects  and  engineers,  but  may  also  be  required  for  professions  in  media  and  journalism, 
hospitality  or  accountancy.  Traineeships  that  are  part  of  ALMP  for  young  unemployed 
persons  are  typically  also  highly  regulated.  In  contrast,  open-market  traineeships  (to  be 
understood  as  those  in  which  no  educational  institution  participates  in  the  definition  of  the 
learning content and in the organisation of the traineeship) are subject to much less regulation 
and their definition and organisation is generally left to the bilateral agreement of the parties 
involved.  Type  5  traineeships,  i.e.  those  involving  trainees  and  host  organisations  from 
different countries, are less common at present6. 

Regulatory framework 

5 

6 

Based  on  the  classification  suggested  in  European  Commission  (2012a),  Study  on  a  comprehensive 
overview on traineeship arrangements in Member States (henceforth “the Traineeship study”, available 
http://ec.europa.eu/social/main.jsp?catId=738&langId=en&pubId=6717&visible=1.  Annex 
at 
II 
reproduces the executive summary of the study). 
See section 4.4. for more detail on transnational traineeships. 

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The  regulation  of  traineeships  differs  considerably  not  only  between  the  different  types  of 
traineeship,  but  also  across  Member  States.  At  one  end  France  regulates  all  types  of 
traineeships directly under a series of laws, while in countries such as the Bulgaria, or the UK 
there is no specific national legal framework for trainees7. In six Member States (CY, IE, LT, 
LU, LV, UK), no legal definition of traineeships exists. Moreover, while traineeship contracts 
tend  to  be  offered  as  a  common  practice  in  most  EU  Member  States,  less  than  half  of  the 
Member States have provisions in place regarding duration, remuneration or social protection 
coverage  of  traineeships,  and  practices  with  regard  to  these  elements  differ  widely.  Among 
the  issues  addressed  is  whether  repeated  traineeships  are  possible  with  the  same  employer, 
and whether trainees should be compensated and, if so, by how much and whether minimum 
wage rules should be applied. 

Table  1  summarises  the  situation  in  terms  of  these  key  regulatory  issues  in  EU  Member 
States:  Clearly,  differences  in  the  regulatory  framework  are  rather  important  –  in  particular 
remuneration and social protection issues are not regulated in 11-12 Member States. It is also 
remarkable  that  in  11  Member  States  there  are  still  legal  and  administrative  barriers  to 
trainees coming from another Member State. 

Table 1. Key differences in regulatory framework 

Issue 

Yes 

No 

Unclear 

Legal definition of traineeships 

Legal provisions on duration 

Legal provisions on remuneration  

AT,  BE,  BG,  CZ, 
DE,  DK,  EE,  EL, 
ES,  FI,  FR,  HU,  IT, 
MT,  NL,  PL,  RO, 
SE, SI, SK 

BE,  BG,  DE,  EE, 
EL, ES, FI, FR, HU, 
IT,  LU,  MT,  PT, 
RO, SI, SK, UK 

EL, ES, FR, HU, IE, 
LT,  MT,  PT,  RO, 
SE, SI, SK 

Legal  provisions  on  social  security 
protection  

AT,  BE,  BG,  CY, 
EL, FR, LT, RO, SE 

Absence  of  legal  and  administrative 
barriers  for  trainees  from  other  EU 
MS  

DK, IT, MT, SE, SI  BE, DE, EL, ES, 
FR, IE, LU, LV, 
NL, PL, RO 

Traineeship  contract  offered  as  a 
common practice  

AT,  BE,  BG,  DE, 
DK, EE, EL, ES, FI, 
FR,  IE,  IT,  LT,  LV, 

CY, LU, PL 

7 

See Annex II and Traineeship study, pp. 45-50 for details. 

CY, IE, LT, LU, 
LV, UK 

PT 

AT,  CY,  CZ, 
DK, LV, NL, SE 

IE, LT, PL 

AT,  BG,  CY, 
CZ,  DK,  FI,  IT, 
LU,  LV,  NL, 
UK 

CZ,  DE,  DK, 
EE,  ES,  IE,  IT, 
LU,  LV,  MT, 
NL, PT 

DE, 

BE, 
EE, PL 

FI,  HU,  PL, 
SI, SK, UK 

AT, 
BG, 
CZ, 
CY, 
EE, FI, HU, 
LT, PT, SK, 
UK 

CZ, 
HU, 
RO, SE, SK 

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MT, NL, PT, SI, UK 

Source: Traineeship study, European Commission (2012a) 

An example of a stricter regulatory approach: the US  

In terms of regulation, it is interesting to compare the case of the EU with the US because, 
although the labour market is less regulated and the level of youth unemployment is different, 
the concerns voiced over traineeships are very similar and the trend toward a higher number 
of traineeships is equally prominent.  

On  traineeships,  the  U.S.  clearly  follows  a  more  stringent  regulatory  approach  than  many, 
probably the majority, of EU Member States. The primary law governing workers’ rights to 
fair  compensation  is  the  Fair  Labor  Standards  Act  of  1938  (FLSA).  The  FLSA  requires 
employers to provide the federal minimum wage to most workers. To determine whether an 
intern qualifies as an “employee” under the FLSA, the Department of Labor has developed a 
six-point test for employers to apply, based on a 1947 Supreme Court ruling. All six points 
must be met in order to determine that trainees are not fully protected “employees”; if only 
one of the points is not met, the trainee would be considered an employee under the FLSA, 
and hence entitled to receive the federal minimum wage. These six points include (Edwards, 
Hertel-Fernandez, 2010): 

1.  The training, even though it includes actual operation of the facilities of the employer, 

is similar to that which would be given in a vocational school; 

2.  The training is for the benefit of the trainee;  
3.  The trainees do not displace regular employees, but work under close observation;  
4.  The  employer  that  provides  the  training  derives  no  immediate  advantage  from  the 
activities  of  the  trainees  and  on  occasion  the  employer’s  operations  may  actually  be 
impeded; 

5.  The  trainees  are  not  necessarily  entitled  to  a  job  at  the  completion  of  the  training 

period; 

6.  The employer and the trainee understand that the trainees are not entitled to wages for 

the time spent in training.  

Particularly points 1-4 are quite restrictive. In practice however these guidelines are hobbled 
by legal and technical issues making their application far from straightforward; partially as a 
result of this they have not been extensively enforced until recently (Curiale, 2010). However, 
this may be changing as a result of suits filed by former interns against several well-known 
corporations  (Time  Magazine,  May  2  2012).  This  is  reportedly  already  leading  to  a 
perceptible drop in unpaid internships (USA Today, July 3, 2012).  

Lack of official statistics  

Partly as a result of the wide variation in type and official recognition of traineeships, there 
are no official statistics on trainees. Academic research on traineeships is scarce, particularly 
as  regards  quantitative  studies,  and  tends  to  be  fragmentary  and  country-  and  situation-
specific. This document is mainly based on the Traineeship study, which provides a first EU-
wide evidence base on traineeships. A few studies and survey results have been quoted when 
particularly relevant; however it has to be born in mind that their methodology is different, so 
that caution is needed in comparing their results directly.  

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Although  the  lack  of  official  statistics  makes  it  impossible  to measure  precisely  trends  over 
time,  available  evidence  suggests  that  traineeships,  whether  national  or  transnational,  are 
becoming significantly more common in the EU and worldwide. There is wide consensus that 
traineeships are becoming a standard feature of young people’s transition from education and 
training to the labour market. The Traineeship study found a definite upward trend over time 
in almost all Member States. For example, a study found for Germany that the share of those 
who did a post-graduate traineeship was 25% amongst 18 to 24 year olds, while only 17 % of 
those  in  the  30-34  age  bracket  had  done  one  after  their  studies.  In  the  US,  the  National 
Association of Colleges and Employers found that 50% of graduating students had followed 
internships  in  2008,  up  from  the  17%  reported in  a  1992  study  by  Northwestern  University 
(Greenhouse,  2010).  In  Japan,  too,  the  so-called  'freeters'  or  furita  are  becoming  more 
common (Hommerich, 2008). 

2.3. 

Benefits and costs of traineeships  

The spread of traineeships is due to a growing realisation of their benefits to both trainees and 
employers, while also responding to the overall economic and labour market situation. These 
benefits have implications at the macro level, too. Traineeships also have a series of costs, at 
individual level and for society at large.  

Trainees 

A positive traineeship experience can play an important role in building the foundation of a 
successful career. This is because traineeships, owing to their practical, hands-on nature, are 
increasingly being seen as an important contribution in terms of acquiring useful skills, both 
during studies and later, during the transition to employment and the subsequent career.  

Traineeships  can  supply  students  with  several  benefits:  1)  the  ability  to  relate  classroom 
concepts  to  practical  applications,  2)  an  improved  knowledge  of  industry  career  paths,  3) 
crystallization  of  interests  and  career  ambitions,  4)  a  reduced  shock  upon  entering  the 
workplace, and 5) faster advancement (Coco, 2000).  

Traineeships  have  further  been  found  to  enhance  productivity  by  increasing  students’ 
knowledge  base  and  motivation  (Beard,  1998);  and  to  improve  not  only  the  transition  from 
school  to  work,  but  even  students’  grades  while  education  is  ongoing  (e.g.  in  accounting) 
(Knechel, 1987; English, 1993). 

The exposure to the workplace enables students to obtain a realistic preview of the business 
environment  and  corporate  culture  and  helps  bridge  the  transition  from  university  life  to 
professional  work  life,  notably  in  the  case  of  expatriate  trainees  (Feldman,  1998). 
Traineeships  can  enhance  students’  chances  of  receiving  job  offers  at  the  firms  where  they 
trained,  or  elsewhere  due  to  signalling  effects  related  to  previous  traineeships;  work 
performance  of  professionals  that  have  had  a  traineeship  experience,  as  measured  by  their 
annual performance valuation, was better compared to those that had not, and their retention 
and promotion rates are also significantly higher (Höft and Hell, 2007; Siegel, 2010, 2012). 

Trainees  also  face  costs.  The  major  component  is  the  living  cost  and,  in  the  case  of 
transnational  traineeships,  costs  due  to  the  need  to  move  to  another  country;  in  addition, 
particularly after the end of the studies, a traineeship involves an opportunity cost in terms of 
foregone  earnings  (as  compared  to  regular  employment);  if  the  traineeship  is  during  the 
studies, the opportunity cost might take the form of a possible delay in finishing one’s studies. 
Finally, trainees face search costs for finding and applying for a traineeship.  

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Host organisations 

One  of  the  most  important  benefits  of  traineeships  to  host  organisations  consists  of  a  better 
screening of job applicants, based on direct experience with the candidate rather than 'signals' 
(Stolorz, 2005), as shown by higher retention rates of employees who were in traineeships in 
the same company8. Traineeships also may help attract more or better job candidates. Finally, 
host  organisations  can  utilise  the  trainees,  alongside  regular  employees,  to  conduct  certain 
work  activities  at  lower  or  no  cost,  while  benefiting  from  trainees’  up-to-date  academic 
knowledge and skills. In a 2011 survey of 218 top, senior and middle level managers in the 
UK,  52%  said  that  the  main  reason  for  taking  on  interns  was  to  identify  new  talent  for  the 
organisation,  while  17%  said  it  was  to  get  work  done  more  cheaply.  A  95%  share  of  them 
believed that interns were useful to the organisation9.  

A  company’s  involvement  in  a  well-designed  traineeship  programme  can  also  be  seen  as  a 
mark  of  business  quality.  The  provision  of  quality  traineeships  is  sometimes  utilised  as  an 
integral  part  of  an  organisation’s  CSR  (Corporate  Social  Responsibility)  and  employer 
brand10.  

The  costs  of  a  traineeship  for  a  host  organisation  include,  besides  any  direct  remuneration, 
mainly the training costs, typically related to the time that trainers or other employees have to 
spend overseeing the trainee. In addition, costs include the provision to the trainee of office 
space and equipment. Unfortunately, no studies quantifying training costs could be identified. 
Edwards  and  Hertel-Fernandez  (2010,  p.  5)  provide  two  examples  which  can  be  taken  to 
represent a plausible range of training costs for the US (US$ 400 and US$ 3500). In a more 
dated  contribution,  McCaffery  (1979)  estimated  the  total  direct  costs  of  one  specific 
traineeship programme at US$ 2000 per trainee. 

While training costs and oversight costs can be fairly limited in case the tasks assigned to the 
trainee  are  easy,  they  can  be  fairly  substantial  in  ambitious,  high  quality  programmes.  Box 
two provides two case studies. 

8 

9 
10 

A 2011 report on recruitment practices of UK firms found that there are on average 70 applicants for 
each traineeship position, and that three out of five leading companies would not interview candidates 
who have not done work experience with them, irrespective of the university they have attended or the 
results they have achieved. The report also states fears of recruitment experts that less well-off students 
will  lose  out  and  that  “with  few  firms  offering  an  internship  wage,  all  but  the  very  wealthy  will  be 
eligible for top jobs.” See High Fliers Research (2011). 
However, the share drops to 85% amongst all respondents. See Heath, Potter (2011).  
The recent UK Common Best Practice Code for High-Quality Internships states that greater access to 
high-quality traineeships can help an organisation meet its CSR objectives by promoting social mobility 
and diversity in the professions. In a similar vein, in both the Netherlands and Slovenia, the AIESEC 
traineeship  programme  also  explicitly  links  the  offer  of  quality  traineeships  with  the  promotion  of  a 
positive  and  strong  employer  brand  and  CSR  which,  in  turn,  can  enhance  an  organisation’s 
attractiveness to the best talent. 

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Box 2. Case studies - the benefits and costs of providing high quality traineeships 

Swedbank's 'Young Jobs' project 

In  2010  Swedbank  launched  the  project  “Young  Jobs”.  The  idea  is  to  use  Swedbank’s 
extensive network of branches to encourage the creation of trainee positions for people aged 
between 18 and 24. The objective is not only to create trainee positions at the Swedbank and 
related Savingsbanks' branches, but also to encourage the bank’s corporate clients (businesses 
and municipalities) to offer trainee positions themselves. The bank’s employees have a good 
understanding of the local companies’ operations as well as their needs and are therefore in a 
good position to identify possible job openings. The project is conducted in cooperation with 
local employment offices.  

To  support  the  project,  the  website  www.ungajobb.se,  was  created  where  young  people  can 
search for new trainee opportunities while companies can enroll in the project. 

The total number of traineeships created by the project was 3,000 – including 400 traineeships 
within  Swedbank,  1,600  traineeships  in  the  Savings  banks'  600  branches  as  well  as  1,000 
further traineeships at partner companies. 

The  traineeships  included  three  months  of  practice  also  supported  by  the  Swedish  Public 
Employment Service Centre. Two full days of education, as well as five days of tutoring by 
staff members ensured the high quality learning content. 

Swedbank’s branch office managers evaluated the project positively: 

- 
brand. 

- 

- 

- 

- 

82 per cent said that Young Jobs has actively contributed in strengthening the bank’s 

65 per cent believed that Young Jobs has increased the confidence of personnel. 

64 per cent answered that they are continuously planning to invite more trainees. 

26 per cent stated that the project has increased business among current clients. 

18 per cent point out that the project has resulted in new clients. 

Of the approximately 400 apprentices within the bank 70% have been offered some form of 
employment after their internships. The costs of the programme for the bank are estimated at 
around € 1,200,000 per year, i.e. about € 3,000 per trainee.  

Audi traineeship project in Brussels 

Audi Brussels has recently launched an initiative together with two Belgian VET schools with 
the aim of providing a high quality technical traineeship. Although the traineeship borders on 
an  apprenticeship  in  terms  of  the  organisation  and  ambition  of  the  scheme,  it  represents  a 
useful example of an unpaid, but high quality traineeship. 

Audi provides traineeship placements for 10 VET students, who spend a total of 600 hours in 
75 days with the company (one day per week plus a 3 week workshop). The objective is to 
offer all the trainees a job at the end of the programme. The costs faced by Audi include two 
persons  (not  full-time)  following  the  programme,  organizing  a  course  for  10  trainers,  and 

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about  € 300,000  to  adapt  the  facilities  to  the  needs  of  the  programme.  Audi’s  motivation  is 
that it allows the company to train its future employees, thus reducing later recruitment costs. 
The programme is also part of the company's CSR policy; it helps to reinforce the image of 
Audi in Belgium. 

Sources: Swedbank AB, Audi AG 

Socio-economic costs and benefits 

At  macro-economic  level,  besides  the  direct  productivity  benefits,  traineeships  can  improve 
labour  market  matching,  ease  education-to-work  transitions  and  promote  labour  mobility, 
notably by decreasing search costs - both for enterprises looking for new staff and for young 
people,  who,  having  just  begun  their  work  experience,  may  be  uncertain  about  their  skills, 
preferences  and  the  direction  in  which  to  develop  their  career.  The  reduction  in  matching 
costs  appears  particularly  beneficial  in  those  countries  where  the  costs  of  hiring  and 
dismissing an employee are highest. 

Social  costs  can  also  arise  if  traineeships,  particularly  repeated  ones,  displace  regular 
employment, notably entry-level positions usually offered to young employees. In light of the 
long-term  benefits  of  successful  traineeships,  however,  the  bulk  of  costs  appear  to  be 
concentrated in low-quality traineeships with little learning content, where the time spent on 
the  traineeship  does  neither  lead  to  significant  productivity  gains  nor  entails  positive 
signalling  effects.  These  traineeships  therefore  provide  little  or  no  benefit  in  terms  of  the 
education-to-work  transition.  Other  social  costs  relate  to  the  spread  of  unpaid  or  low-paid 
traineeships  which  may  limit  the  career  opportunities  of  those  from  disadvantaged 
backgrounds,  particularly  in  certain  professions.  Against  the  background  of  raising  student 
tuition fees and tightening labour markets it may indeed be increasingly difficult for students 
or graduates from less wealthy backgrounds to afford to work for free. Such difficulties are 
exacerbated in the case of transnational traineeships.  This  in  turn  would  prevent  firms  from 
identifying the most talented for some of their future top jobs. 

3. 

CONSULTATIONS AND STAKEHOLDERS VIEWS 

Public and social partner consultation  

On  18  April  2012  the  Commission  adopted  the  communication  ‘Towards  a  job-rich 
recovery’11, which was accompanied by the staff working document 'Quality Framework for 
Traineeships'12  that  launched  a  public  consultation.  The  Commission  asked  stakeholders 
whether there is a need for such an initiative, what should be the scope of the initiative, which 
quality elements would have to be included and what form the initiative should take. Between 
11  September  and  23  October  2012,  social  partners  were  consulted  on  their  views  on  the 
possible direction of an EU initiative on a quality framework for traineeships. 

The  public  consultation  received  over  250  responses  of  which  29  came  from  national  and 
regional  governments  (ministries  and  agencies),  8  from  trade  unions,  40  from  employers’ 
organisations and business representatives, 14 from youth (umbrella) organisations, 33 from 
education institutions, 11 from other organisations and 117 from private individuals.  

11 
12 

COM(2012)173, 18.04.2012 
SWD(2012)99, 18.04.2012 

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Trade  unions,  as  well  as  NGOs,  youth  organisations,  educational  institutions,  agencies 
involved in transnational traineeships and most individual respondents generally supported a 
Commission  initiative  (some  asking  for  a  binding  legal  instrument,  others  preferring  non-
binding recommendations); employers' organisations, chambers of commerce and industry – 
while  acknowledging  the  positive  role  of  traineeships  in  school-to-work  transitions  and  in 
acquiring skills – typically adopted a more sceptical stance, with some questioning the need 
for  an  EU  initiative.  Those  contesting  the  need  for  an  EU  initiative  mostly  came  from 
Member  States  with  comparatively  well-developed,  structured  apprenticeship  systems  and 
traineeship markets (e.g. Germany, Austria, and Denmark).  

Both  employer  organisations  and  Member  States  often  referred  to  the  need  to  keep  the 
framework  sufficiently  flexible  so  that  diversity  of  national  systems  and  practices  can  be 
taken  into  account.  Opponents  of  EU  action  argued  that  minimum  requirements  for 
traineeships  should  not  be  set  at  the  European  level,  due  to  a  lack  of  EU  competence 
particularly  on  the  issue  of  remuneration.  Concerns  were  also  raised  about  traineeship 
schemes becoming overburdened with too many legal or administrative procedures that could 
discourage companies from taking on trainees, thus depriving young people of valuable work 
experience opportunities.  

Opinions  about  the  scope  of  a  possible  initiative  were  varied  as  well.  Many  educational 
institutions  preferred  to  keep  the  scope  limited  to  traineeships  that  are  part  of  study 
curricula/programmes; while other respondents including most employers suggested limiting 
the  framework  to  'open  market'  traineeships.  Some  comments  (mainly  from  the  world  of 
education) enquired why apprenticeships should not be covered by the initiative.  

On  the  quality  elements  most  respondents  agreed  with  the  Commission's  analysis/definition 
(traineeship  contract,  clear  objectives  and  content,  limited  duration,  adequate  social 
security/remuneration  etc.),  however  businesses  and  employers'  organisations  in  particular 
argued that remuneration and social protection issues may not fall under EU competence and 
in any case small businesses would have problems applying them. 

Several  respondents  urged  the  Commission  to  provide  financial  support  to  increase  the 
number of traineeships, eventually by launching large scale EU-level programmes. 

In their replies to the first-stage consultation EU social partners confirmed the positions taken 
in  the  public  consultation.  At  the  Social  Dialogue  Committee  meeting  of  23  October  2012 
employer's organisations expressed the readiness to start discussions on traineeships as part of 
the  EU  social  partner  autonomous  negotiations  on  a  Framework  of  Action  on  Youth 
Employment.  The  European  Trade  Union  Confederation  explained  that  while  it  is  fully 
committed to participate in the EU social partner's negotiations on the Framework of Action, 
it considered that the discussions under the Framework are not, at this stage, the appropriate 
place for negotiations on traineeships under Article 154 TFEU. 

Small and medium enterprises  

The Commission launched a specific consultation of small and medium enterprises (SMEs). 
The  Commission  sent  out  a  questionnaire  targeted  at  SMEs  through  UEAPME.  The  results 
highlighted  that  small  businesses  face  particular  difficulties  when  offering  traineeship 
placements due to relatively higher levels of costs. However, traineeships offered  important 
advantages  for  SMEs,  in  particular  the  possibility  of  screening  potential  future  employees, 
recruiting and retaining high-skilled workers and enhancing the corporate image at relatively 

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low  cost.  SMEs  favoured  excluding  open  market  traineeships  from  the  scope  of  any  EU 
initiative.  Any  proposal  by  the  Commission  should  be  non-binding  (e.g.  general  principles) 
and take into account SME specificities. SMEs called for increased EU resources to increase 
the availability of traineeships, both national and transnational. 

Consultations within the European Commission 

DG  Employment  has  been  collaborating  with  DG  Education  and  Culture  on  the  issue  of 
traineeships. Further to the EMPL-EAC cooperation, DG EMPL set up an Impact Assessment 
Steering  Group  with  the  involvement  of  SG,  SJ  and  DGs  EAC,  ECFIN,  ENTR,  HOME, 
INFSO/CNECT, MARKT and RTD.  

Recommendations from the Commission Impact Assessment Board 
An earlier version of this paper was submitted to the Commission Impact Assessment Board, 
which examined it on two occasions, , requesting improvements to clarify the policy context 
and  the  problem  definition,  to  better  demonstrate  the  necessity,  added  value  and 
proportionality  of  EU  action,  and  to  better  present  the  available  policy  options  and  the 
effectiveness and efficiency of the presented avenues for action. The document was therefore 
amended  by,  inter  alia,  including  more  detail  on  the  Treaty  procedure  for  Social  Partners 
consultation  and  on  the  concrete  problems  faced  by  trainees,  by  adding  some  new  sections 
and  an  annex  on  market  failure,  by  a  clearer  specification  of  subsidiarity  considerations 
applying  to  this  case,  and  by  adding  substantially  more  detail  on  the  ways  in  which  policy 
action could take form and the foreseeable impacts of the various options considered. It was 
also  clarified  that  traineeships  are  not  employment  contracts  in  most  Member  States,  and 
details  were  added  on  which  aspects  justify  an  EU  action  and  which  do  not.  It  was  also 
indicated that a more detailed assessment of impacts will be carried out following the results 
of this consultation, in case the Commission decides to present a proposal. 
Traineeship survey by the European Youth Forum 

The European Youth Forum (EYF) is the most important Europe-wide umbrella organisation 
representing  young  people  in  the  EU.  It  conducted  an  online  survey  in  2011  among  (ex)-
trainees about their experiences and concerns regarding traineeships. More than 3,000 young 
people  responded  to  the  survey.  Results  (see  Box  5)  confirm  that  there  is  room  for 
improvement in the quality of traineeships.  

As a follow-up to the survey, the European Youth Forum – together with other civil society 
organisations  and  31  MEPs  –  presented  a  European  Quality  Charter  on  Internships  and 
Apprenticeships.  The  Charter  underlines  that  traineeships  and  apprenticeships  should  be 
primarily a learning experience and should not replace jobs; that a traineeship should be based 
on a written contract and should be limited in time; that a mentor/supervisor should provide 
guidance throughout the traineeship; that the trainee should receive reimbursement of costs or 
should have the right to receive food, housing, and public transportation tickets instead; that 
decent remuneration should be provided for work carried out additional to the  requirements 
outlined in the contract; and that clear evaluation criteria of the traineeship period is needed. 

4. 

PROBLEM DEFINITION 

4.1. 

Nature and extent of problems 

The  analysis  carried  out  in  the  Traineeship  study  shows  that  concerns  with  traineeships 
usually  take  four  main  forms:  insufficient  learning  content,  lack  of  or  low  compensation, 

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unsatisfactory working conditions, and low level of intra-EU trainee mobility (see Box 3 for a 
summary of the qualitative findings and Table 2 for some relevant quantitative evidence). 

Box 3. Main concerns identified by the Traineeship study  

Insufficient learning content of the traineeship is one of the most frequent problems. Learning 
content  is  more  likely  to  be  formally  defined  where  an  educational  institution  is  involved. 
Traineeships involving just the trainee and the employer  more often  lack content definition. 
This  does  not  necessarily  mean  that  these  placements  are  entirely  devoid  of  structure  and 
content.  For  example,  in  the  UK  many  employers  voluntarily  provided  well-structured 
traineeships  with  pre-defined  content.  It  is  noteworthy  however that  even  in  Member  States 
where regulation exists to define the content of traineeships (e.g. AT, LU), there are concerns 
that employers do not always abide by these rules.  

Another worrisome point in relation to traineeships was found to be the lack of proper social 
protection  coverage  (most  often  only  health,  and  in  some  cases  occupational  risk/accident 
insurance  is  being  offered  to  the  trainee).  Traineeships  which  form  part  of  government 
sponsored  programmes  increasingly  oblige  employers  to  pay  the  trainees’  social  security 
contributions, either in full or in part through subsidies (e.g. in CY, EL, PL). 

The  lack  of  compensation  or  low  pay  and  the  prospect  of  exploitation  are  general  concerns 
mainly  in  the  case  of  traineeships  in  the  open  market  and  mandatory  professional  training 
schemes. This is one of the most common theme and starkest message emerging in the study 
as  well  as  in  public  debates,  available  literature,  and  information  provided  by  trainees.  The 
risk of substituting regular employment by traineeships is greater in Member States with high 
unemployment and/or unfavourable labour market conditions for young people (e.g. EL, ES, 
IT,  PT).  However,  using  traineeships  as  free  labour  is  a  growing  phenomenon  also  in  other 
countries, where young people might have to do several traineeships before they find a proper 
job.  Whether  traineeships  should  be  paid  or  not  is  a  contentious  issue  in  many  countries. 
Employers’  organisations  often  argue  that  trainees  gain  work-related  experience  which  will 
improve  their  employability,  while  taking  on  board  a  trainee  can  be  time-consuming  and 
resource intensive for the host organisation.  

On the other hand, trainees who are not or insufficiently compensated have to rely on other 
sources  of  financial  support,  including  own  and/or  family  resources.  This,  in  turn,  raises 
concerns about equity of access, since those from less privileged backgrounds may not be able 
to draw on such resources in order to undertake traineeships to gain work-related experience 
and enhance their employability. Trainees are reported to be in many cases asked to carry out 
tasks  usually  performed  by  regular,  fully-paid  staff  for  which  they  receive  no  or  low 
compensation.  The  issue  of  no  or  low  trainee  compensation  (associated  with  poor  trainee-
related  terms  and  conditions  such  as  lack  of  social  security  coverage)  is  critical  because  a 
significant  segment  of  young  people  may  have  to  undertake  a  series  of  traineeships  before 
securing  stable  employment.  This  can,  in  turn,  seriously  impede  their  ability  to  become 
financially  self-sufficient  and  lead  an  independent  and  autonomous  life.  Further,  there  are 
indications of a gender ‘pay gap’ in traineeships with a larger proportion of women in unpaid 
or low paid placements.  

Finally, low quality seems to be more common where there is a lack of monitoring and clear 
traineeship linked objectives.  

Source: Traineeship study, European Commission (2012a) 

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Table 2. Indicators on the Quality of Traineeships 

Indicator 

Learning content 

Data 

Source(s) 

Country

Mentor' s performance: good or excellent 

55% 

EYF Survey, p.19 

EU-wide

Mentor'  s  performance:  less  than  satisfactory 
or not satisfactory 

Relevance  to  respondents'  field  of  study: 
good or excellent 

Relevance  to  respondents'  field  of  study:  not 
satisfactory 

Beneficial  in  terms  of  extending  experience 
and practical knowledge 

Good mentoring 

Useful in terms of learning outcomes 

Duties/tasks at a good level 

The traineeship content was good 

Usefulness for professional development 

Usefulness for professional orientation 

Good mentoring 

The tasks contributed to learning 

Compensation 

Traineeship was paid 

Compensation covered living expenses 

Working conditions 

18% 

EYF Survey, p.19 

EU-wide

55% 

EYF Survey, p.19 

EU-wide

6% 

EYF Survey, p.19 

EU-wide

83% 

81% 

70% 

67% 

64% 

57% 

66% 

61% 

88% 

Fuchs / Ebert (2008) 

Fuchs / Ebert (2008) 

DE 

DE 

Briedis / Minks (2005)  DE 

Briedis / Minks (2005)  DE 

Kravietz (2006) 

Kravietz (2006) 

Kravietz (2006) 

Kravietz (2006) 

DE 

DE 

DE 

DE 

 OPALA survey (2010) 

FI 

51%  

25% 

EYF Survey, p. 15 

EYF Survey, p. 15 

EU-wide

EU-wide

Feeling of being exploited 

61% 

Fuchs / Ebert (2008) 

DE 

Traineeship plans lacking / not followed / not 
useful 

62% 

Counselling  /  support  during  the  traineeship 
was sufficient 

81% 

Briedis / Minks (2005) 

 OPALA survey (2010) 

DE 

FI 

General level of satisfaction 

Trainees  completely  satisfied  with 
internship 

their 

25% 

Internocracy (2010) 

UK 

Traineeships felt to be poor quality 

30-40% Traineeship study, p.831  UK 

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Comparison mandatory vs. open-market traineeships 

VET students satisfied/very satisfied  

88% 

Traineeship study, p.151  AT 

University  applied  sciences  graduates  "at 
least satisfied"  

General  University  graduates  "at 
satisfied"  

least 

80% 

Traineeship study, p.151  AT 

70% 

Traineeship study, p.151  AT 

Young graduates "at least satisfied"  

52% 

Traineeship study, p.151  AT 

A  first  group  of  problems  relates  to  the  high  share  of  traineeships  characterised  by 
insufficient  learning  content.  Insufficient  learning  content  might  mean  that  the  host 
organisation does not ensure a proper induction training or the trainee does not get a proper 
explanation/description of the work of the organisation and the underlying issues within the 
industry; it might mean that the host organisation does not ensure a mentor who follows the 
work  of  the  trainee  and  supports  him  or  her  throughout  the  traineeship,  or  the  appointed 
mentor does not fulfil his or her tasks. A traineeship with insufficient learning provides only a 
limited (or no) support to smooth education to work transitions since the trainee will acquire 
less practical skills by the end of the traineeship then he or she optimally could have acquired 
through a high quality traineeship.  

Learning  content  tends  to  be  most  deficient  where  there  is  no  well-structured  written 
agreement  between  the  trainee  and  the  host  organisation,  specifying  the  purpose  of  the 
traineeship, the skills to be learnt, the roles and responsibilities of all parties involved, and the 
supervision,  mentoring  and  monitoring  arrangements  (Traineeship  Study,  p.  137).  These 
problems  have  been  especially  observed  for  open  market  traineeships;  in  the  traineeships 
where  learning  institutions  are  involved  problems  exist,  but  are  less  common  because  the 
learning  institution  usually  ensures  minimum  standards  ahead  of  the  traineeship,  through 
guidelines and selection of host organisation, and ex post if negative feedback is received. A 
case  study  about  a  low-quality  traineeship  and  the  reaction  by  the  learning  institution  is 
described in Box 4.  

A share of 18% of traineeships is reported to be unsatisfactory with respect to learning content 
in the EYF survey (see Box 5; other surveys find even higher shares; see Table 2). This is less 
than  the  share  of  unpaid  traineeship,  which  surveys  results  consistently  indicate  at  around 
50%, indicating that many unpaid traineeships are satisfactory from a content viewpoint. 

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Box 4. Case study: A low learning content experience  

“A traineeship experience abroad is important, but in my case it’s been a wasted opportunity” 
says  G.C.,  who  did  a  traineeship  as  a  fourth  year  law  student.  “I  applied  for  a  five-month 
traineeship  organised  by  my  university  at  a  law  firm  in  London,  in  the  department  for 
international  property  purchases.  There  were  almost  exclusively  lawyers  from  my  country 
there. My role was essentially making photocopies. My working time was the same as for the 
colleagues, I tried to be proactive but de facto I just did secretarial work like handling email 
and archiving documents. There may have been contributing factors for this, as the law firm 
had  just  moved  and  I  did  not  know  English  perfectly.  But  I  was  not  the  only  one  in  that 
situation;  in  the  firm  there  were  other  two  boys  whose  judgement  was  equally  negative.  I 
know  that  their  tutor  intervened  doing  some  checks  on  the  traineeships  although  I  have  the 
impression  that  my  own  complaint  did  not  have  any  effect.  Once  back  I  explained  to  the 
responsible  department  in  my  university  how  things  had  gone  and  that  there  was  no 
underlying project to make the traineeship useful. Nothing happened, but I know that in other 
such  cases  traineeships  were  stopped.  My  impression  was  that  they  were  just  looking  for 
people to put to work for free; they were continuously looking for trainees, certainly not with 
training  purposes.  However  the  experience  has  not  been  totally  negative,  I  noticed  that  my 
traineeship abroad is the first thing they note in interviews, but it could have had more value’. 

Source: abridged from Repubblica degli Stagisti, E. Della Ratta, 8 March 2010  

A second group of concerns relate the lack of or the low level of compensation. The EYF 
survey indicates that only every fourth trainee was remunerated or compensated enough to be 
able  to  cover  his  or  her  expenses.  Lack  of  compensation  explains  concerns  about  equity  of 
access  and  merit-based  career  opportunities,  and  raises  issues  about  employers  using 
traineeships  as  a  form  of  unpaid  employment  with  ‘cheaper’  trainees  being  used  for  entry 
level jobs and/or other job vacancies instead of regular staff. In the UK, a 2011 survey found 
that only 62% of permanent employees thought that trainees were treated fairly (Heath, Potter 
2011). 

A  third  group  of  problems  relate  to  working  conditions  other  than  compensation,  such  as 
long working hours, substandard working conditions, lack of coverage for health and safety or 
occupational risks, lack of clarity on the applicable legal regimes, equal treatment, and so on.  

Table  3  supplies  some  greater  detail  on  the  concrete  problems  typically  encountered  by 
trainees, their practical concerns and ideas for improvement, as identified by an online poll of 
a  UK  trainee  organisation,  “Changing  internships  in  the  UK”.  The  ranking  of  votes  also 
provides  some  insight  on  the  relative  importance  of  problems,  as  perceived  by  trainees, 
although it should be stressed that online polls are not statistically representative and have a 
purely  indicative  nature.  Apart  from  the  specific  aspect  about  the  London-centric  nature  of 
UK  internships,  which  is  due  to  a  high  concentration  of  professional  services  firms  in  the 
capital, the concerns put forward are very similar to those put forward in other Member States 
(see also European Youth Forum survey results in Box 5).  

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Table 3. Internships for change poll, UK 

Ideas  

Pay interns National Minimum Wage 

Interns should be viewed as potential employees, not cheap labour 

Votes 

20.90% 

13.70% 

A  youth-driven  quality  mark  to  identify  the  organisations  with  the  best
internships 

11.40% 

Organisations should have to adhere to a minimum set of standards 

The London-centric nature of internships should be challenged 

Profit-making organisations should pay interns 

7.90% 

5.60% 

5% 

Organisations should define the nature of the work before the internship starts  4.40% 

Set  up  an  organisation  you  can  turn  to  protect  your  rights  if  being  treated
unfairly. 

3.50% 

Make employers aware that they are supposed to have educational value for the
intern 

3.20% 

Internships should be advertised to everyone 

2.80% 

Send a letter to companies/MPs advertising unpaid internships reminding them 
of their duty of care/law 

2.60% 

Distinguish between interns and volunteers 

Interns should be offered cheaper accommodation 

2.30% 

2.30% 

Unpaid internships should not require a commitment of more than 3 months.  2.30% 

Others 

Total 

Concerns by topic (excl. ‘others’) 

Working conditions, fairness 

Learning content 

Wages and compensation 

11.80% 

100.00% 

39.70% 

30.50% 

29.70% 

Source:  Data  downloaded  from  Internocracy  website  on  October  13,  2012  and  elaborated  by  Commission 
services. The poll is ongoing. 

Finally, a fourth group of problems that is typically not highlighted by trainees’ organisations 
or national analysis but that is of concern from the perspective of the integration of EU labour 
markets  is  the  low  level  of  intra-EU  mobility  for  trainees.  This  has  important  negative 
consequences for the integration of the EU labour markets and prevents young people living 
in  countries  with  insufficient  or  unsatisfactory  traineeship  offer  to  profit  from  better 
opportunities in the EU single market. The problem will be discussed further in section 4.4.  

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Box 5. A closer look at data on traineeships – the European Youth Forum survey 

Given the lack of official statistics, the only quantitative evidence available is represented by 
survey  results.  Although  compiled  from  different  populations  and  using  different 
methodologies, they generally seem to supply encouragingly similar estimates on parameters 
such  as  rate  of  job  retention  after  completion  of  a  traineeship  (which  has  been  estimated  at 
12%, 14% and 16% in three different surveys in different EU countries).  

One of the most important sources on EU traineeships is the European Youth Forum Survey 
conducted among (ex)trainees in the EU from April to July 2011. The 3028 responses provide 
a large enough sample for drawing some conclusions concerning quality concerns related to 
traineeships, as well as the dimension of the problem. 

Most trainees are in their twenties and traineeships typically last between 4 and 6 months. The 
majority of respondents (63%) have done one or two traineeships (but 37 % has already done 
3  or  more)  and  the  most  common  ways  of  finding  a  traineeship  is  by  applying  directly  to 
organisations,  searching  on  the  internet,  and  making  use  of  personal  connections.  With 
regards  to  the  motivation  for  doing  a  traineeship,  improving  their  CV  and  improving  future 
job opportunities were the two most significant factors. Some also wanted to learn more about 
a particular organisation or field of work, or get first-hand experience of working life. A high 
number of trainees also cited a lack of available jobs as a motivation.  

The quality of the traineeship is a core concern of the trainee, and takes precedence over other 
factors  such  as  remuneration.  Although  three  out  of  four  respondents  were  not  (51%)  or 
insufficiently (24%) compensated and had to rely on parental support, savings, or other forms 
of  external  financial  means,  they  seem  more  interested  in  the  potential  gains  from  the 
traineeship than its costs. An example is the traineeship satisfaction rates of the post-studies 
(open market) trainees, which did not differ from the average despite the fact that they more 
often received no or low pay. A 16% share of trainees managed to turn their traineeship into a 
job with their host organisation afterwards. 

A  25%  share  of  trainees  report  not  having  had  a  written  traineeship  agreement  (which  the 
Traineeship  study  identified  as  an  important  quality  indicator).  54%  of  (ex)trainees  were 
completely  satisfied  with  the  mentor’s  performance  (excellent  or  good),  and  further  19% 
evaluated the mentor as satisfactory – meaning that every fourth trainee lacked a good mentor. 
The learning content of the traineeship was relevant to the studies/career interests for 56% of 
the  trainees  (excellent  or  good),  and  satisfactory  for  further  24%;  however  this  was  not  the 
case for every fifth respondent. 

4.2. 

Number and share of low quality traineeships 

Estimating the number of low quality traineeships is not straightforward and subject to wide 
error margins. The traineeship study estimates that in France and Germany there are at least 
1.5 million trainees each year. Estimates indicate that in Italy the number of trainees is of the 
order  of  half  a  million  every  year,  while  for  the  UK  estimates  indicate  up  to  280,000  open 
market  traineeships  plus  up  to  118,000  students  in  undergraduate  courses  mixing  work 
experience with training. Assuming no substantial differences in the share of trainees in the 

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population  across  the  EU  (admittedly  a  strong  assumption),  this  leads  to  an  estimate  of 
between 4 and 5 million trainees in the 27 Member States in a given year.13

Another  way  to  formulate  an  estimate  is  by  looking  at  the  number  of  tertiary  education 
students  in  the  EU  and  use  this  as  a  basis  for  a  projection  on  the  basis  of  assumed  activity 
rates.  According  to  Eurostat,  in  2010  there  were  19.8  million  students  enrolled  in  tertiary 
education courses (ISCED levels 5 and 6) in the 27 Member States. Assuming that during the 
average  studies  of  4  years  80  %  of  the  students  will  eventually  participate  in  one  or  more 
traineeships of altogether 6 months on average, one arrives at 4 million trainees per year. One 
should add to this those upper secondary level (ISCED 3 and 4) students who may also do a 
traineeship, even if in smaller numbers. This confirms the estimate of 4 to 5 million trainees 
per year. 

To estimate the number of low-quality traineeships, survey results from the European Youth 
Forum  were  used  (“Interns  Revealed:  A  Survey  on  internship  quality  in  Europe,  Brussels 
2011”), which offers the advantages of a relatively large pool of respondents and of a Europe-
wide coverage. An 18.0 % share of respondents indicated that the “mentor performance” was 
unsatisfactory  or  less  than  satisfactory,  and  a  very  similar  share  (18.2%)  classed  as 
unsatisfactory or less than satisfactory the relevance of work performance to the content of the 
studies; either share may be taken to represent a traineeship of insufficient quality. The share 
indicating  a  more  negative  response  (i.e.  not  satisfactory)  was  respectively  8.2%  and  6.5%. 
Applying the lower of the two shares to the estimated total number of traineeships (4 million) 
results  in  about  300  thousand  low  quality  (i.e.  non-satisfactory)  traineeships  per  year,  and 
about 500 thousand insufficient quality (less than satisfactory) traineeships. This value should 
be  seen  as  an  indicative  estimate  only,  taking  into  account  exclusively  the  learning  content, 
not  the  issue  of  compensation.  Under  certain  assumptions,  the  share  of  traineeships  without 
satisfactory learning content can further be estimated at some 20% of all traineeships, and at 
about 50% of unpaid traineeships. 

Table 4. Estimates of the number of traineeships and their characteristics 

Total number of traineeships 

4,500,000 

Insufficient quality 

Low quality 

520,000 

290,000 

Average duration (months) 

4 

Assessing the costs of low quality traineeships is complicated, in the present crisis juncture, 
by  the  fact  that  trainees  may  not  have  a  meaningful  alternative  in  the  short  run,  as  job 
opportunities are scarce and there is stiff competition even for traineeship positions (the EYF 

13 

An alternative way of estimating the number of traineeships is the following: assuming that the number 
of  traineeships  as  a  percentage  of  the  ISCED  levels  5-6  student  population  is  roughly  constant,  we 
extrapolate the ratios for three large member States (FR, DE, IT), for which estimates of the number of 
traineeships  are  available,  to  the  entire  EU  student  population.  This  yields  a  result  of  more  than  6 
million traineeships. This result confirms that 4.5 million is a prudent estimate. 

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survey  indicates  that  40%  of  post-study  traineeships  were  accepted  because  no  jobs  were 
available). In such cases, the opportunity cost of a bad quality traineeship is reduced.  

Low-quality  traineeships  are  likely  to  affect  more  often  trainees  from  a  less  privileged 
background 

One particularly unwelcome aspect of low-quality traineeships is that they are likely to affect 
more  often  those  from  a  less  privileged  background  and  may  prevent  their  future  access  to 
high-productivity quality jobs in line with their skills and study results.  

It is of course more difficult for the less well-off to support themselves during a low-paid or 
non-paid  traineeship  and  the  spread  of  jobs  for  which  a  traineeships  constitute  a  de  facto 
requirement  reinforces  this  concern.  However,  the  structural  differences  of  the  traineeship 
market from the regular employment market create a further barrier.  

In  search  of  a  regular  employment  relationship,  a  candidate  with  a  weaker  training 
background  will  of  course  be  at  a  disadvantage  against  stronger  candidates,  but  has 
nevertheless  still  a  chance  to  compete  by  reducing  his  or  her  wage  requirements;  the  lower 
reservation  wage  would  also  increase  the  pool  of  possible  alternative  job  offers.  This  is  not 
possible  in  a  traineeship  market  where  often  there  is  no  compensation  at  all.  Available 
positions  will  tend  to  be  awarded  simply  to  those  having  the  best  educational  background, 
possibly  also  including  earlier  work  experiences,  or  other  characteristics  of  value  to  the 
recruiting organisation. Those with a weaker educational background thus risk having no way 
of  overcoming  initial  disadvantages,  whenever  the  number  of  positions  is  fewer  than  the 
number  of  candidates  as  is  the  case  currently.  In  summary,  those  from  a  less  wealthy 
background as well as those with weaker educational credentials will more often be victims of 
low-quality traineeships because they have less scope for selecting the host. 

4.3. 

Problem drivers and trade-offs: The role of market failure 

The analysis above shows that while the majority of traineeship positions on offer do provide 
adequate  quality,  a  substantial  share  does  not.  An  important  question  is  what  are  the  key 
drivers  of  this  problem  and  whether  it  is  due  just  to  factors  such  as  the  current  economic 
crisis  or  to  special  characteristics  of  the  traineeship  market  that  make  it  advisable  to  adopt 
specific measures.  

Market  failure  plays  a  more  important  role  in  traineeships  than  in  regular  employment 
contracts  because  a  much  greater  share  of  the  benefits  that  the  trainee  obtains  from  the 
arrangement  is  not  easily  definable  and  quantifiable,  and  hence  asymmetric  information 
likely to be more important. One of the main benefits, the possibility to be hired, materialises 
even after the end of the traineeship (see Annex VI). Therefore, the trainee cannot effectively 
compare  the  quality  of  the  various  options  with  their  respective  costs,  as  is  the  case  in  any 
normal market transaction. 

As for host organisations, at present there are few incentives for them to improve the quality 
of traineeship positions. First, owing to high demand for traineeships the host organisation is 
under  little  pressure  to  adopt  any  quality  standard  to  attract  candidates,  and  at  any  rate  is 
normally  under  no  legal  obligation  to  do  so.  Second,  the  lack  of  generally  accepted  quality 
standards does not provide hosts with any guidance as to how to improve the quality if they 
wanted to.  

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Overall,  the  main  incentives  for  a  company  or  other  host  organisation  to  provide  good 
quality are currently either their intention to hire trainees in the near future or their wish to 
maintain  a  good  reputation  as  employers  or,  more  generally,  out  of  respect  for  Corporate 
Social  Responsibility.  Indeed,  according  to  the  EYF  survey,  those  trainees  that  were  later 
recruited by their host organisation were much more frequently sufficiently paid (67%) than 
the average rate of 25%; the same result is apparent from an analysis of the hiring behaviour 
of participants in a Quality Label initiative in Italy (see Box 6).  

However, an organisation that does not intend to hire and does not assign a particular value to 
its reputation faces few other disincentives to limit the training content to the minimum and 
may  just  use  traineeships  as  a  source  of  cheap  labour  (‘free-riding  behaviour’).  This  set  of 
incentives  and  disincentives  explain  why  open  market  traineeships  are  significantly  more 
affected by low quality than the other types of traineeships, where actors with a specific role 
in ensuring quality are present. 

Box  6.  Comparing  high  quality  with  average  traineeships  using  data  from  a  quality 

label experience 

The Italian trainees’ organisation Repubblica degli Stagisti has launched a voluntary scheme, 
“OK  Stage”  whereby  host  organisations  commit  to  respect  a  quality  charter  formulated  by 
the  organisation.  The  traineeship  conditions,  published  on  the  site  of  Repubblica  degli 
Stagisti  include  commitments  on  fair  treatment.  Currently,  36  host  organisations  have 
adopted the charter. It is interesting to compare the traineeships conditions offered by these 
quality traineeships with the average for Italy.  

• 
All  these  traineeships  offer  remuneration  –  a  minimum  of  200  euros  per  month  for 
student traineeships and 500 euros for traineeships after university graduation. The average 
net  compensation  for  university  graduates  amounts  to  643  euros  per  month.  In  Italy, 
according  to  the  Repubblica  degli  Stagisti  traineeship  organisation  (RdS),  only  47.6  %  of 
traineeships were paid; note however that while the quality charter calls for compensation it 
did not specify its level.  

The average rate of hiring after completion of the traineeship was 55%, compared to 

• 
an estimate of 12.3% for traineeships as a whole in Italy (RdS, 2010).  

The  much  higher  rate  of  hiring  among  participants  confirms  the  link  between  quality  and 
intention to hire on the part of the organisation. 

Trainees also face a cost in changing companies and the duration of the traineeship is not very 
long anyway. As a result, they are often ‘trapped’ into completing a bad quality traineeship, in 
the hope that this will at any rate give them some kind of positive return (i.e. a mention on 
their CV) compared to nothing - or even a negative signal to potential future employers - if 
they quit the traineeship.  

All  these  factors  –  asymmetric  information;  lack  of  general  quality  standards;  lack  of 
disincentives to firms to offer low quality traineeships; incentives to trainees to stay on such 
traineeships – are key problem drivers underlying current market failures as they create results 
in  a  long-term  equilibrium  in  which  the  market  is  unable  to  screen  out  lower  quality 
traineeships, which may remain on offer indefinitely and which may coexist with a majority 
of  good  quality  offers  (this  mechanism  is  explained  in  more  detail  in  Annex  VI;  see  also 
Curiale (2010), Edwards, Hertel-Fernandez (2011).  

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Quality and compensation 

One element which should be reasonably clear and which could, in theory, help the market to 
screen  out  bad  quality  traineeship  offers  is  compensation.  Indeed  quality  and  compensation 
are  found  to  be  positively  correlated,  and  in  addition  low  or  unpaid  traineeships  are  more 
likely to be of bad quality. Unfortunately however this does not solve the market failure on 
quality, as there can be good reasons for a high quality traineeship to be unpaid. In particular, 
a  traineeship  with  high  training  cost  (see  Box  2  for  some  relevant  examples)  may  be 
economically sustainable for the host organisation only at reduced or zero pay levels, given 
relatively low trainee productivity.  

Compensation and labour market conditions 

Low compensation is not only linked to the characteristics of the traineeships itself, but also 
to the structural characteristics of the labour market, in particular to the general level of labour 
demand, labour market regulation, the existence of labour market segmentation, and so forth.  

High youth unemployment will tend to increase the number of candidates for each available 
traineeship position, while negative growth prospects will induce businesses to curtail hirings, 
one of the main motives for taking on trainees, but possibly also to increase traineeship offers 
as  replacement  for  more  costly  regular  employment.  Abundance  of  candidates  is  likely  to 
induce  host  organisations  to  offer  unpaid  instead  of  paid  traineeships  or  to  reduce 
compensation for new positions.  

Compensation and legal status 

If demand and supply for traineeship positions were in greater  balance  than is currently the 
case, some form of compensation would probably be generally be paid to trainees even in the 
absence of specific regulation. However, given the oversupply of trainee candidates, rules on 
minimum compensation come to play an important role. 

In most countries, trainees are not considered employees, and, as such, their rights, terms and 
conditions,  including  remuneration  are  not  tightly  defined  and  regulated,  at  least  as  regards 
certain types of traineeships. In general, legal provisions for the trainee’s terms and conditions 
in  most  countries  are  very  fragmented  and  do  not  cover  all  types  of  traineeships  in  a 
consistent and coherent way. As shown in Table 1, most countries do not foresee, or may not 
enforce, minimum compensation.  

There is no consensus on the issue of the appropriateness and level of trainee compensation. 
The  main  reason  for  not  paying  wages  to  trainees  is  probably  linked  to  the  idea  that 
traineeships should be distinguished by employment contracts and be mainly about training. 
This line of reasoning has a long tradition and is embodied e.g. in the US regulatory approach. 
In addition, binding rules on minimum compensation are generally believed to have positive 
effects on equality but negative ones on employment levels.  

Trade-offs  

There  is  clearly  a  trade-off  between  ensuring  availability  of  traineeship  positions  and 
imposing  a  minimum  level  of  compensation.  It  is  less  clear,  however,  what  would  be  the 
effects  of  increasing  trainee  compensation  on  the  labour  market  as  a  whole.  In  a  recent 
contribution,  Dolton  and  Rosazza  Bondibene  (2012)  found  that  the  negative  employment 
effects  of  minimum  wages  are  particularly  strong  for  young  people.  Widening  the  scope  of 

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minimum compensations to traineeships could have similar effects, at least in countries where 
traineeships  are  not  subject  to  minimum  compensation.  On  the  other  hand,  it  could  have 
positive  effects  on  equity  of  access  and  income  inequality.  Businesses  could  face  higher 
labour costs with some negative effect on profitability and competitiveness, while at the same 
time possibly benefitting from better skills matching and higher retention rates.  

As for the other employees, theory suggests that the net effect will generally depend on the 
degree  of  substitutability  between  trainees  and  regular  workers.  If  trainees  and  regular 
workers can easily substitute one for another, higher compensation for trainees would result in 
less traineeship positions and employment gains for regular workers. Conversely, if trainees 
and  workers  are,  instead,  complementary,  demand  for  regular  employees  too  should  drop. 
Which of the two effects will dominate is an empirical question that it is difficult to answer at 
present. The impact is also going to depend on the degree of labour market segmentation.  

4.4. 

Quality issues and transnational traineeships 

Low  quality  is  likely  to  affect  the  development  of  transnational  traineeships  even  more 
seriously than domestic traineeships. This is because the problem of the lack of information 
about the quality of traineeships becomes more acute in an international setting: 

•  The  differences  in  standards  and  the  wide  range  of  diversity  in  labour  market  and 
traineeship  regulation  across  Member  States  make  the  situation  in  terms  of  quality 
standards even fuzzier than at home, and informal learning through contacts and networks 
about the quality of traineeships gets more difficult; 
Ignorance  of  local  conditions  by  foreign  trainees  makes  the  awareness  of  rights  more 
limited and complaining more difficult; 

• 

•  Foreign trainees can screen companies with greater difficulty only; 
•  Foreign  trainees  may  face  higher  costs  in  changing  companies  if  not  satisfied.  Their 
investment in going abroad is bigger and the greater sunk costs incurred create a stronger 
incentive to complete a traineeship even if it is low quality. 

Although a traineeship placement in a different country can contribute to the increase of the 
employability  of  a  young  person  (similarly  to  the  completion  of  studies  abroad),  still 
relatively  few  young  people  complete  a  transnational  traineeship.  The  2011  Eurobarometer 
shows  that  53%  of  young  people  in  Europe  are  willing  or  keen  to  work  in  another  EU 
Member State. Young people are much more mobile than the labour force as a whole, as less 
than  3%  of  European  workers  are  currently  living  outside  their  home  country.  Demand  for 
international  placements  funded  under  the  Lifelong  Learning  Programme  (Erasmus  and 
Leonardo da Vinci) systematically exceeds supply. Similarly, traineeship placements offered 
by the European Commission attract a large number of applicants partly due to the high level 
quality.  

Study  mobility  is  overwhelmingly  more  popular  than  company  placements;  within  the 
Erasmus  programme,  it  is  undertaken  on  average  by  about  5  out  of  6  beneficiaries.  The 
duration of study mobility too is almost double that of placement mobility. This seems to be 
corroborated by results of a survey by Deloitte (Deloitte, 2012) on students and graduates in 
five  Central  European  Member  States  (CZ,  LT,  LV,  PL,  SK)  indicating  that  domestic 
job/traineeship  experiences  outnumber  international  ones  by  ten  to  one,  even  though  young 
people from these Member States seem to be more mobile than in some other Member States. 

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Table 5. Share of transnational traineeships 

Indicators 

Erasmus Programme 

Quantification Source(s) 

Year 

Country

Total number of Erasmus students 

231 408 

Total  number  of  Erasmus  work 
placements (traineeships) 

40 913 

Share of work placements in pool of 
participants to Erasmus programme 

≈ 17% 

(1/6) 

Leonardo Programme 

Leonardo mobility visits 

≈ 78 000 

number 

Total 
traineeships (Erasmus + Leonardo) 

transnational 

of 

≈ 119 000 

Erasmus 
Fact 
Figures 

Erasmus 
Fact 
Figures 

Erasmus 
Fact 
Figures 

Leonardo 
Fact 
Figures 

Leonardo 
Fact 
Figures 

& 

2010/2011  EU wide 

& 

2010/2011  EU wide 

& 

2010/2011  EU wide 

& 

2010/2011  EU wide 

& 

2010/2011  EU wide 

Total number of traineeships 

4 500 000 

Share of transnational traineeships 2.60% 

2010/2011  EU wide 

2010/2011  EU wide

The number of transnational traineeships may be estimated only very roughly given the lack 
of  statistics  on  transnational  open  market  traineeships.  Assuming  these  to  be  20-25%  of 
Erasmus and Leonardo traineeships (see Table 5), the total number is probably in the range of 
150,000, compared to 4.5 million, i.e. around 3%.  

The contrast between the high interest for studying abroad, and the low share of transnational 
traineeships, suggests that institutional factors, such as lack of information, are holding back 
development  of  the  market.  If  a  young  person  does  not  know  what  he  or  she  can  expect  in 
terms  of  conditions,  learning  content,  social  protection,  remuneration  etc.  in  a  foreign 
placement,  his/her  willingness  to  participate  will  be  limited.  Organisations  active  on  the 
international  traineeship  market  (e.g.  Europlacement)  confirm  that  there  is  high  student 
demand  for  international  traineeships  once  a  certain  level  of  quality  is  guaranteed.  It  seems 
therefore likely that there is significant potential for growth (at least on the demand side) if 
the quality problem can be convincingly addressed. 

Need to improve access to information on transnational traineeships documented by study  

A  study  commissioned  by  DG  EAC  on  conditions  to  promote  transnational  traineeships  in 
Leonardo  and  Erasmus 
indeed  gives  a  strong 
(European  Commission,  2011b) 
recommendation  to  improve  access  to  information  on  the  legal  and  regulatory  differences 
relevant to traineeships between Member States and to introduce more concrete requirements 
for the overall organisation of traineeships.  

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Besides  direct  EU  support,  other  public  and  private  transnational  mobility  schemes  offer 
services to students as well as to young people not in education and training. A recent study 
on  mobility  developments  in  school  education,  vocational  education  and  training,  adult 
education  and  youth  exchanges  commissioned  by  the  European  Commission  (European 
Commission, 2011a) identifies 1000 learning mobility schemes in Europe, in addition to the 
EU-funded  Lifelong  Learning  sub-programmes  for  Comenius,  Grundtvig  and  Leonardo  da 
Vinci  and  the  Youth  in  Action  Programme.  Furthermore  the  study  shows  that  work 
placements  are  becoming  an  increasingly  popular  type  of  mobility  activity,  indicating  that 
“employability”  is  seen  as  an  important  learning  outcome.  However,  recognition  and 
documentation  of  knowledge,  skills  and  competences  acquired  by  participating 
in 
transnational mobility is still undeveloped in many schemes. Common quality guidelines on 
traineeships would be strongly relevant to these programmes 

Given persistent and sizeable skill mismatches in EU Member States, the lack of development 
of  international  traineeships  seems  to  represent  a  lost  opportunity  to  reduce  structural 
unemployment. A traineeship could constitute a way for trainees to try international mobility 
without a large initial commitment, while businesses could use traineeships as a first step to 
develop international recruitment, useful especially in case of domestic skill shortages. 

Finally, given the strong boost to language learning during a period of several months spent 
working  in  a  foreign  country,  disincentives  to  intra-EU  trainees’  mobility  may  have  a 
persistent  cost  in  terms  of  lost  productivity.  Research  by  Williams  (2005)  indicates  that  the 
use of a second language in the workplace raises earnings by about 5 to 10 per cent.  

5. 

LEGAL BASIS AND SUBSIDIARITY 

Legal basis 

According  to  Article  153  TFEU,  the  Union  shall  support  and  complement  Member  States 
activities in the field of, inter alia, working conditions, social security and social protection of 
workers,  and  also  the  integration  of  persons  excluded  from  the  labour  market  and  the 
combating of social exclusion. 

Pursuant to Article 153 para. 2. b) TFEU, the European Parliament and the Council may adopt 
Directives in the field of employment and social policy.  

Alternatively, according to Article 292 TFEU, the Council can adopt recommendations on the 
basis  of  a  Commission  proposal.  Occupational  Safety  and  Health  legislation  considers 
trainees  and  apprentices  as  covered  by  the  scope  of  the  Directives  based  on  framework 
Directive of 1989, whose basis is Art 153 TFEU.  

However,  it  should  be  noted  that  the  provisions  of  Article  153  TFEU  do  not  apply  to  pay 
(Article  153  para.  5  TFEU).  Hence,  the  problems  relating  to  the  low  level  of  trainee 
compensation will have to be dealt with at another level, notably by Member States and social 
partners. 

Mobility in education and training not only forms a central objective in the EU's educational 
policy but is also an integral part in of the freedom of movement of persons under Article 45 
TFEU – a fundamental freedom protected by the Treaty. Given the transnational dimension of 
traineeships, actions of individual Member States alone will not achieve the objectives of the 

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proposed initiative - to comprehensively improve the quality of traineeships undertaken in the 
EU. 

The Charter of Fundamental Rights of the European Union also contains a number of rights 
and  freedoms  which  may  be  relevant  to  measures  that  may  be  decided  concerning 
traineeships, in particular its Article 21 (Non-discrimination), Article 29 (Right of access to 
placement services), Article 31 (Fair and just working conditions) and Article 32 (Prohibition 
of child labour and protection of young people at work). 

Subsidiarity  

Generally,  great  diversity  of  situations  among  Member  States,  or  very  different  societal 
preferences  are  arguments  in  favour  of  decentralised  solutions,  as  they  can  be  tailored  to 
national or even local needs and preferences.  

However,  in  the  case  of  traineeships,  the  difference  of  labour  market  institutions  does  not 
seem to play a major role, as the nature of the complaints and concerns put forward is very 
similar  everywhere,  and  quality  problems  in  traineeships  are  frequent  even  in  the  Member 
States where the labour market situation of young people is more favourable. The Traineeship 
study found that only in five Member States there was no presence of questionable employer 
practices with regard to traineeships14.  

Another  criterion  commonly  used  to  assess  whether  an  EU-wide  solution  is  preferable  is 
whether a standardised solution offers operational advantages or cost savings. In this regard, it 
does appear that an EU-wide solution presents several advantages.  

•  First,  the  quality  guidelines  adopted  or  proposed  so  far  generally  look  very  similar  (see 
box  7  and  Annex  IV),  irrespective  of  the  organisation  drafting  them.  Differences  reflect 
mainly remuneration - which is sometimes covered and other times not, depending also on 
the  national  regulation  on  this  point  –  and  the  presence  of  individual  binding  elements, 
such  as  limitations  of  successive  traineeships  which  are  usually  absent  from  voluntary 
charters.  This  suggests  that  there  is  no  great  need  of  adaptation  of  quality  standards  to 
local conditions. 

•  Second, an EU wide-solution would have clear benefits in terms of intra-EU mobility of 
trainees.  Young  people  would  find  it  easier  to  accept  a  traineeship  in  another  country  if 
standard  or  harmonised  rules  gave  them  a  clear  knowledge  of  what  they  can  expect  in 
another country. Greater trainee mobility would contribute to achieving a more integrated 
EU labour market through better matching and sustainable job creation. 

•  Third,  experience  shows  that,  owing  to  coordination  problems,  the  definition  of 
internationally accepted quality standards can be faster if supranational institutions adopt a 
coordinating and supporting role. The EU is best placed for this, as there seems to be little 
or no movement towards spontaneous development of international quality standards.  

Through  an  initiative  in  this  sense,  the  EU  could  concretely  support  Member  States  in 
implementing  the  EU  2020  employment  guideline  nr  8,  in  particular  ‘enacting  schemes  to 
help recent graduates find initial employment or further education and training opportunities, 
including  apprenticeships,  and  intervene  rapidly  when  young  people  become  unemployed.’ 
Providing guidance to the Member States that is operational and can be readily implemented 
at national level appears all the more useful given the acuteness of the crisis and a track record 

14 

See Traineeship study, p. 94. 

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of delays in addressing the problems of traineeships. It is also fully in line with the spirit of 
the European Semester. 

The  Commission  invited  already  in  2007  "Member  States  to  promote  internships  with  a 
strong  link  to  training  or  study  curriculum  and  to  define  adequate  frames  for  doing  so"15. 
More  broadly,  the  Commission  has  frequently  called  for  better  work-to-school  transitions, 
which implicitly includes action on traineeships, as this has long been recognised as a priority 
area. Also the resolution and conclusions of the 101st ILO Session on the International Labour 
Conference have called for “regulating and monitoring apprenticeship, internship and other 
work-experience  schemes,  including  through  certification,  to  ensure  they  allow  for  a  real 
learning  experience  and  not  replace  regular  workers”  (ILO  2012).  Despite  these  calls 
however action from Member States has been patchy and the regulatory framework generally 
remains fragmented and unsatisfactory (see Table 1).  

The  traditional  European  employment  strategy  approach  could  be  used  to  induce  Member 
States to reform traineeship regimes, but would lead to greater differentiation in the resulting 
framework than instruments such as recommendations or legislation determining the content 
of traineeship regimes. This would be suboptimal particularly in terms of the need to address 
existing barriers to trainee mobility.  

Finally, a standardised EU solution seems to be a logical pre-condition for extending EURES 
to  apprenticeships  and  traineeships,  as  requested  by  the  European  Council  conclusions  of 
28/29 June 201216. This is due to the need to prevent the risk that without ensuring standard 
quality  requirements  for  traineeships  advertised  within  EURES,  support  through  EURES  is 
provided to low quality traineeships that will not help smooth education to work transitions. 

6. 

POLICY OBJECTIVES 

The general objectives of an initiative in this domain are:  

(1) To facilitate education-to-work transitions 

High  quality  traineeships  contribute  to  increasing  the  employability  of  young  people. 
Traineeships as a form of labour market entry for graduates should be stepping stones in the 
progression  to  a  regular  employment,  ensure  a  rapid  increase  in  workers’  productivity  and 
help reduce precarious employment. The objective should therefore be increasing the number 
of good quality traineeships and reducing the extent of low-quality instances and abuse.  

(2) To promote mobility in order to reduce mismatches in the European labour market 

To  reduce  structural  unemployment,  the  promotion  of  learners'  and  of  workers'  geographic 
mobility  within  the  EU  should  be  stepped  up,  given  the  existence  of  marked  skill  and 
demand/supply mismatches in the labour market. A development of transnational traineeships 
is  a  key  tool  in  this  respect.  Prospective  trainees  who  consider  undertaking  their  training  in 
another EU Member State should have a clear reference to check quality criteria and not be 
discouraged  by  uncertainty  about  administrative  formalities;  legal  concerns,  or  contractual 
obligations. 

15 

16 

Communication  COM(2007)498.  Also  COM(2009)257  referred  generally  to  the  need  for  traineeship 
places:  "Companies  should  also  continue  to  offer  traineeship  places  to  develop  the  employability  of 
students 
www.consilium.europa.eu/uedocs/cms_Data/docs/pressdata/en/ec/131388.pdf 

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In order to meet these general objectives, the following specific objective has been identified: 

•  To improve the quality of traineeships in the EU.  

The operational objectives would be 

(1)  To  encourage  host  organisations  to  offer  traineeships  providing  good  quality  learning 
content,  decent  working  conditions  and  which  are  a  good  stepping  stone  for  entering  the 
labour market.  

(2) To increase the transparency and quality of information on traineeship positions. 

7. 

POLICY COHERENCE – CONTRIBUTION TO EUROPE 2020 

An  initiative  on  a  quality  framework  for  traineeships  is  closely  related  to,  and  usefully 
complements, several other European initiatives. Facilitating education to work transitions, as 
well  as  promoting  mobility,  is  high  on  the  Europe  2020  agenda.  In  2010  the  Europe  2020 
flagship  initiative  'Youth  on  the  Move'  announced  that  the  Commission  would  propose  a 
quality  framework  for  traineeships  including  the  transnational  dimension,  the  role  of  the 
social partners and corporate social responsibility aspects.  

In  light  of  the  further  deterioration  of  youth  access  to  the  labour  market,  the  Commission 
launched the ’Youth Opportunities Initiative’ in December 2011. One of the main actions of 
the  initiative  consists  in  the  Commission’s  support  for  Member  States  to  use  the  European 
Social Fund more efficiently, among others for supporting traineeship places, as is already the 
case in some countries. In addition, Commission support to high quality traineeships under the 
Erasmus and Leonardo da Vinci programmes will be increased in the remaining programme 
period,  and  a further budget increase  will be proposed in the "Erasmus for All" programme 
starting  in  2014.  The  Youth  Opportunities  Initiative  also  confirms  earlier  commitments  to 
present a quality framework for traineeships in 2012. 

Skills are a core asset for economic growth, as is good quality education and training systems 
that  facilitate  young  people's  transition  from  school  to  work.  In  this  context,  16  Member 
States have this year received a Country Specific Recommendation on "enhancing access to 
lifelong  learning,  upgrading  the  skills  and  competences  of  the  workforce  and  increasing  the 
labour  market  relevance  of  education  and  training  systems,  VET".  A  very  frequent 
recommendation 
learning,  whether 
apprenticeships  or  work  placements  in  companies.  Guiding  criteria  for  quality  traineeships 
appear particularly useful for countries where the education and training authorities have little 
experience or tradition of working in partnership with businesses. 

the  availability  of  work-based 

increase 

to 

is 

Action on improving traineeship quality is also related to the debate around the recognition of 
qualifications,  and  in  particular  the  recognition  in  the  home  Member  State  of  a  traineeship 
accomplished abroad. This is of particular importance for the regulated professions but might 
concern other professions as well. For traineeships in the regulated professions, the legislative 
proposal  amending  Directive  2005/36/EC  foresees  the  introduction  of  a  compulsory 
recognition mechanism. 

Political attention to traineeships is maintained in the 2012 Employment Package and is also 
on the agenda of international organisations, notably the ILO.  

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Developing  a  quality  framework  for  traineeships  also  contributes  to  the  Commission's 
endeavour  to  lift  obstacles  to  the  full  enjoyment  by  citizens  of  their  EU  rights,  and  notably 
their right to free movement.  

8. 

POSSIBLE AVENUES FOR EU ACTION 

Situations in which markets fail at ensuring minimum quality levels are not uncommon. They 
are  usually  addressed  either  by  a  regulation  imposing  minimum  standards  (regulatory 
approach, sometimes replaced by self-regulation), or by measures to increase the transparency 
of the market.  

The analysis in section 4 provides a few pointers for actions that could improve the situation 
by tackling the causes of the problems. Not all possible actions are suitable for action at EU 
level, in light of legal or operational considerations. Table 6 illustrates some possibilities.  

Table 6. Problems, problem drivers and possible levels of action 

Problem  

Problem driver 

High  share  of 
traineeships 

low-quality 

information 

Lack  of 
for 
trainees on existing rights and 
quality standards 

Lack  of  general  quality 
standards hinders adoption of 
host 
good 
organisations 

practices 

by 

Lack  of  transparency  on  the 
individual 
the 
quality  of 
traineeship  offered  and  lack 
of  effective  disincentives  to 
free-riding 

Different 
action 

Set 
up 
website(s) 

levels  of  EU 

information 

Encourage 
voluntary 
adoption  of  engagements  on 
quality (‘quality label’) 

Introduce  a  set  of  quality 
guidelines 

Introduce binding legislation 
(e.g.  on  quality  standards, 
banning  unpaid  or  repeated 
traineeships etc. 

Possible policy response at EU level  

Given  the  link  between  low  quality,  market  failure  and  lack  of  transparency,  one  policy 
response should aim at increasing transparency at all stages. This could mean in practice: 

•  Clarifying the existing legal framework on traineeships: the Traineeship study has shown 
that the legal framework on traineeships is fragmented and complicated, leading to a lack 
of  certainty  on  the  legal  rights  and  obligations  of  trainees  and  host  organisations.  This 
could  be  done  through  an  effort  at  providing  better  quality  information  through 
appropriate tools; 

•  Simplifying the legal framework through appropriate regulatory reforms. A good starting 

point could be the provision of guidelines from best practice; 

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• 

Introducing mechanisms for feedback on the experience from individual traineeships, e.g. 
through appropriate websites; 

•  Providing  minimum  requirements  on  the  learning  content  and/or  on  traineeship 

conditions, either through regulation or via soft law. 

Actions could be taken, depending on the types of traineeships, at different levels, involving 
different actors and different tools. The EU could:  

• 
improve the transparency of traineeship regulation through more accessible information; 
•  encourage  voluntary  action  by  stakeholders  (host  organisations,  social  partners  etc.)  to 
enhance  the  quality  of  traineeships,  for  instance  through  the  establishment  of  quality 
labels; 
launch actions  under the European  employment  strategy  to encourage Member States to 
improve the quality of traineeships; 
introduce non-binding instruments (recommendations or guidelines); or  
introduce binding legislation.  

• 
• 

• 

Possible scope of application 

Regulatory theory suggests that market failure in delivering quality can generally be tackled 
in two ways, either by enhancing the quality and availability of information on the market, or 
by  imposing  quality  standards.  Either  approach  could  enhance  the  effectiveness  of 
traineeships in ensuring good transitions from education to work. In the following, a number 
of measures based on the first or the second approach are explored. 

Open-market  traineeships  seem  to  represent  an  obvious  candidate  for  initiatives  given  that 
they represent the most problematic segment, but alternatives exist: the scope of the measures 
could  be  either  widened  or  restricted  to  apply  to  cross-border  traineeships  only,  or  to 
traineeships with a duration above three months (on the grounds that these are those for which 
the expectations by trainees of a significant learning content are highest, as would be the costs 
for  low  quality).  Another  issue  is  whether  sectoral  specificities  would  warrant  tailoring  or 
limiting measures to certain industries (see Annex V for an overview of the sectoral spread of 
traineeships). 

The  social  partners  may  wish  to  consider  one  or  more  of  the  below  measures,  requiring 
different levels of engagement of EU institutions. The contents of these areas may be adapted 
in various ways. A first rough assessment of the impact / effectiveness of each option is also 
provided (a more detailed assessment of impacts will be carried out following the results of 
this consultation, in case the Commission decides to present a proposal).  

8.1. 

No initiative at EU level (baseline scenario) 

Description: There is no sign that the quality concerns discussed above would decrease in the 
future.  As  mentioned  in  Section  4  and  in  Annex  VI,  economic  incentives  are  such  that  an 
equilibrium around the current share of low quality traineeships is likely to be sustained in the 
absence of policy action.  

Furthermore, the prolonged economic crisis may lead to a further deterioration in traineeship 
quality.  As  outlined  in  Annex  VI,  one  of  the  main  reasons  for  offering  a  high-quality 
traineeship consists of search for new talent in view of hirings. Job creation however is being 
affected by the crisis. As fewer firms are interested in hiring, it seems likely that the share of 

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good  quality  traineeships  will  decline  in  the  immediate  future.  Furthermore,  it  may  be 
speculated that increasing cost-cutting pressure could also tend to boost the number of low-
quality traineeships, in some cases also at the expense of regular employment. 

Certain  Member  States  might  introduce  regulation,  possibly  on  the  lines  of  the  French 
Cherpion  law,  and  social  partners  might  adopt  quality  charters  at  national  or  sectoral  level; 
these however would not be coordinated and therefore would retain the fragmented nature of 
the  current  landscape,  with  its  negative  effects  on  trainee  mobility.  The  Commission  will 
continue to pursue the objective of improving mobility and labour market transitions of young 
people  in  particular  from  education  to  employment,  in  the  wider  framework  of  the  Europe 
2020 strategy and as a follow-up of the 2012 Employment Package, but without any specific 
instrument/tool focusing on traineeships. The Traineeship study provides a first overview of 
the traineeship arrangements in the Member States and lays a basis for more transparency of 
arrangements.  

Finally, another possibility is that given increasing public concern about trainee exploitation, 
there  might  be  a  greater  trend  towards  adoption  of  voluntary  quality  charters  by  host 
organisations. This is however unlikely to change the situation perceptibly, for two reasons. 
First, adoption rates for existing  voluntary charters  are very  low, amounting to a few dozen 
only for initiatives launched in Italy and in the UK. Second, and more cogently, those firms 
that are likely to adopt the charters are likely to be those that are already now offering a high 
quality  traineeship;  the  providers  of  low-quality  traineeships  are  unlikely  to  be  swayed 
significantly. 

Looking  at  developments  on  the  ground,  there  seems  to  be  limited  movement  towards 
spontaneous  development  of  global  or  EU-wide  quality  standards.  While  it  is  possible  that 
there  are  further  national  or  international  initiatives  in  order  to  enhance  the  quality  of 
traineeships, the overall share of low quality traineeships could be expected to remain roughly 
constant or even increase: the crisis may lead businesses to scale back new hirings, which are 
one of the main reasons for offering high-quality traineeships, and labour market entrants may 
have revised downwards their expectations. 

8.2. 

Creation of an information website  

Description:  Setting  up  a  website  with  a  traineeship  panorama  (based  on  the  Traineeship 
study - e.g. within the EURES portal, or by the social partners), containing regularly updated 
information on traineeship conditions and the legal framework in each Member State, would 
constitute a non-regulatory approach to increase the availability of general information about 
traineeships.  As  a  bolder  option,  the  website  could  also  allow  trainees  to  give  feedback  on 
their individual traineeship experience with a host organisation, transforming the nature of the 
information from purely general to specific. However the cost and legal implications of this 
possible facility should be carefully considered. 

Pros:  A  properly  designed,  user-friendly  website  would  allow  a  better  spread  of  –  and  in 
particular easier access to – general information on national legislation of traineeships, on the 
availability  of  different  types  of  traineeships  in  Member  States.  This  would  reduce  search 
costs for trainees, could improve matching and could also have a positive effect on increasing 
the availability of candidates for transnational traineeships. Over time, greater availability of 
candidates could stimulate also an increase in interest by businesses, particularly those facing, 
for whatever reason, difficulty in attracting domestic applicants for certain vacancies. 

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An  information  website  could  be  implemented  at  a  limited  cost  (i.e.  establishment  and 
management/regular  update  of  the  information  present  on  the  website).  While  there  is  no 
compliance  cost  for  Member  States  or  host  organisations,  there  would  be  some  budgetary 
implications  for  the  organisation  running  the  website  (possibly  the  European  Commission). 
Procedures  for  making  sure  that  the  information  is  always  up-to-date  would  have  to  be 
established. 

In  its  basic  formulation,  this  tool  addresses  part  of  the  lack  of  information  problem,  i.e.  the 
lack of general information on standards, but does not provide information on the quality of 
specific traineeship positions on offer. Hence, the impact of this option on traineeship quality 
is  useful  but  modest,  being  limited  to  greater  awareness  of  rights  and  average  traineeship 
conditions. It could have a stronger effect on stimulating transnational traineeships.  

Implementing  the  option  of  allowing  trainees  to  assess  or  rate  their  traineeship  experience 
would instead create a fairly strong incentive for host organisations to improve the quality of 
their  traineeship  offer,  as  their  reputation  would  benefit  from  being  shown  to  offer  high 
quality  traineeship  conditions.  Provision  of  low  quality  traineeships  would  be  strongly 
discouraged, first by making the reputational loss for host organisations concrete and secondly 
because it would be harder to find applicants. 

Cons:  On  the  other hand,  this  option appears  difficult to implement  from a legal  viewpoint, 
particularly  at  EU  level.  Appropriate  safeguards  (such  as  moderation,  rules  on  leaving 
feedback, checks to prevent individual users to have a disproportionate effect on ratings, etc.) 
should  be  found  to  prevent  the  risk  of  penalising  host  organisations  from  inappropriate 
feedback.  This  option  may  also  discourage  host  organisations  that  are  uncertain  about  the 
quality of (some of) their traineeships to supply traineeships at all, possibly even high quality 
ones, out of fear of receiving negative ratings. 

Table 7. Foreseeable impact of the creation of an information website 

Potential 
Impact 
quality 
traineeship  

on 
of 

Voluntary 
(V)  /  Soft 
law  (SL)  / 
Regulator
y  solution 
(R)  

on 
for 

Impact 
demand 
traineeships 
positions (D – 
– 
domestic 
CB  –  cross-
border) 

on 

Impact 
compliance 
costs 
for 
businesses  = 
on 
impact 
supply 
of 
traineeship 
positions 

Flexible 
solution 

Impact 
on 
complian
ce 
costs 
for SMEs 

na 

0 

D: 0 

CB: + 

0 

0 

Yes 

Key:  
0 : zero or negligible impact 
(+) / (-) : slight positive (negative) but uncertain impact 
+ / -: possible positive/ negative impact 
++ / -- : likely positive/ negative impact 
+++/--- : very likely positive/ negative impact 

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8.3. 

Quality label for traineeships 

Description:  A  set  of  quality  principles  for  traineeships  could  be  elaborated  in  cooperation 
with  social  partners,  specifying  minimum  quality  guidelines  for  the  format  and  learning 
content  of  the  traineeship  (see  box  7).  Companies,  educational  institutions,  employment 
services  and/or  other  relevant  actors  could  voluntarily  commit  to  respect  the  guidelines  for 
trainees (e.g. in the form of a voluntary code of conduct), and, in exchange for that, publicise 
themselves  as  ‘fair  to  trainees’  or  similar.  In  order  to  provide  a  reputational  benefit  for 
participating  businesses/host  organisations,  the  label  should  be  advertised  and  managed 
directly by an adequate private or public body or stakeholder group giving some guarantee of 
independence  and  impartiality.  The  quality  label  for  traineeships  could  also  include  a 
commitment  by  the  host  organisation  on  providing  remuneration  and  social  security 
treatment.  Furthermore,  it  is  possible  to  launch  a  quality  label  specifically  in  sectors  where 
there  are  more  concerns  related  to  open  market  traineeships  (e.g.  tourism,  journalism, 
politics/public affairs, creative industries, management consulting, etc.). 

Compliance would not be monitored systematically, but ways would need to be found, either 
at EU or at individual Member State level, to handle complaints by trainees about companies 
not  following  the  code/guidelines.  To  achieve  minimal  compliance  costs,  the  quality  label 
could be attributed to all organisations that would commit to it without advance inspection or 
screening. A certain number of duly justified complaints could lead to the withdrawal of the 
label.  Such  light  organisation  would  allow  the  label  to  be  managed  by  the  companies 
concerned, or by a small external office. The ‘quality label’ approach has been followed most 
intensively  in  the  UK,  though  with  low  take-up  rates  so  far  (see  Annex  IV  for  additional 
details about the UK schemes). 

Pros:  Overall,  this  non-regulatory  approach  has  the  merit  of  encouraging  and  guiding  host 
organisations by providing a reference for quality standards while its voluntary nature ensures 
that it is bearable for host organisations. It goes some way into providing a positive incentive 
for adoption, given that one of the motives for organisations to offer traineeships is improving 
their reputation, which could be enhanced by a quality label. This option might also stimulate 
cross-border traineeships. Its main weakness is that it would presumably have limited or no 
disincentive  effect  for  low-quality  traineeships,  as  low  quality  providers  would  simply  not 
apply for the label.  

The voluntary nature of the commitment seems to make sure that the compliance burden for 
businesses  would  be  acceptable.  Compliance  costs  would  depend  on  how  the  quality  label 
would be managed and handling of complaints organised. The administrative costs related to 
signing  traineeships  agreements,  defining  precisely  roles  within  the  organisation  etc.  would 
rapidly decline over time as the main effort is made once, at the initial set-up. Including in the 
voluntary  charter  commitments  on  pay  would  address  a  typical  complaint,  but  would  also 
affect the compliance cost and possibly take-up. 

Cons: However, there is a risk that few organisations bother to apply for the label, particularly 
as at present demand for traineeships outstrips supply. Furthermore, many of those that apply 
probably will be those that offer high quality traineeships already. Hence the option appears 
useful but of limited impact. The impact on replacement risk would be close to zero as few 
low-quality hosts are likely to apply.  

Table 8. Foreseeable impact of a quality label for traineeships 

EN 

37 

   EN 

 
Measure 
Action 

/ 

Potential 
Impact 
quality 
traineeship  

on 
of 

Voluntary 
/  Soft 
(V) 
law  (SL)  / 
Regulatory 
solution 
(R) 

on 
for 

Impact 
demand 
traineeships 
positions (D – 
– 
domestic 
CB  –  cross-
border) 

on 

Impact 
compliance 
costs 
for 
businesses  = 
on 
impact 
supply 
of 
traineeship 
positions 

Flexible 
solution 

Impact 
on 
complian
ce 
costs 
for SMEs 

Quality label   V/SL 

0/+ 

D: + 

0 

0 

Fairly 

CB: ++ 

Quality  label 
+ 
remuneration 

V/SL 

0/+ 

D: + 

0/(-) 

0(-) 

Fairly 

CB: ++/+++ 

Key:  
0 : zero or negligible impact 
(+) / (-) : slight positive (negative) but highly uncertain impact 
+ / -: possible positive/ negative impact 
++ / -- : likely positive/ negative impact 
+++/--- : very likely positive/ negative impact 

8.4. 

European Quality Framework for Traineeships  

Description:  This  measure  would  consist  in  a  social  partner  agreement  or  a  Commission 
proposal (for a Directive or for a Recommendation) on quality elements, to be transposed by 
Member States in national practice and/or the national legal system. The quality framework 
could include inter alia the elements listed in Box 7. The legal basis would be either Article 
153 2(b) or Article 292 TFEU.  

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38 

   EN 

 
Box 7. Key quality elements identified in the Traineeship study 

A good quality traineeship should enable the trainee to acquire practical skills geared to the 
labour  market  needs  and  complementary  to  the  trainee’s  theoretical  studies  in  order  to 
enhance  the  trainee's  employability.  The  Study  has  identified  a  number  of  principles  that 
characterise a good quality traineeship. Starting point for the formulation of the ‘quality label’ 
is  the  presence  of  a  mandatory  traineeship  agreement. A good quality traineeship should be 
based  on  an  agreement  between  the  trainee  and  the  host  organisation  (i.e.  company,  public 
agency etc.). 

The  traineeship  agreement  should  cover  the  following  elements  (identified  by  the  study  as 
most important):  

• 
Objectives, content and monitoring: Traineeships should enable the trainee to acquire 
practical  skills  complementary  to  his  or  her  theoretical  studies.  The  guidelines  require  that 
educational  content  is  ensured  by  assigning  a  personal  supervisor  or  mentor  at  the  host 
organisation  to  each  trainee.  The  supervisor  guides  the  trainee  through  the  assigned  tasks, 
monitors progress, and explains general work processes and techniques. The supervisor also 
has  to  provide  an  evaluation  of  the  trainee’s  performance  in  the  form  of  a  short  final 
evaluation (1 to 2 pages), which may take the form of a letter of reference. 

• 
Duration:  Open-market  traineeships  should  typically  not  be  longer  than  6  months. 
Mandatory  post-graduation  professional  training  of  doctors,  lawyers,  teachers  and  the  like, 
which  exist  in  most  Member  States,  are  exempted  as  these  traineeships  tend  to  be  highly 
regulated.  A  similar  category  in  this  respect  are  the  in-company  so-called  "traineeship 
programmes" for recruitment at higher levels of management in order to prepare the trainees 
for a high level career in the enterprise.  

• 
Remuneration/cost  compensation:  If  there  is  a  mutual  benefit  for  both  the  host 
organisation and the trainee in terms of knowledge transfer and learning, unpaid traineeships 
may  be  appropriate.  Hence  the  quality  guideline  should  only  stipulate  that  the  written  stage 
agreement  clearly  specifies  what,  if  any,  compensation  and  remuneration  is  offered  (noting 
the  role  that  remuneration  /  cost  compensation  may  have  for  access  to  quality  traineeships, 
and hence labour market chances of (young) people from disadvantaged backgrounds). 

• 
Social  security  provisions:  The  social  insurance  provisions  need  to  be  clarified 
between  the  trainee  and  the  employer.  This  includes  health  insurance  and  insurance  against 
accidents  at  the  workplace.  In  most  Member  States,  students  are  provided  with  social 
insurance  by  the  state  or  their  educational  institution.  Therefore,  they  are  insured  against 
health risks and accidents while undertaking traineeships during their studies. If the trainee is 
not  a  student  anymore  but  the  traineeship  is  covered  by  an  employment  contract,  employer 
and  employee  need  to  fulfill  insurance  obligations  as  stipulated  by  labour  law  in  the 
respective  country.  Alternatively,  the  contractual  arrangement  could  foresee  insurance 
schemes to be paid by the host organisation or the trainee. 

Pros:  The  strength  of  this  approach  is  that  the  quality  framework  would  be  the  same 
framework in all (adopting) Member States. This would therefore address the negative impact 
of the diversity of regulations on the development of international mobility. A framework in 
form of a Directive would be legally enforceable and would ensure that the rights of trainees 
are effectively protected. 

EN 

39 

   EN 

 
The  content  of  the  quality  framework  can  be  drawn  upon  using  the  Traineeship  study.  The 
elements  identified  in  the  study  could  be  complemented  with  a  limitation  of  successive 
traineeships,  and/or  with  a  requirement  to  register  traineeships.  Similar  measures  have  been 
adopted in certain Member States (e.g. France). Limiting the repetition of traineeships by the 
same  person  in  the  same  organisation,  or,  more  boldly,  prescribing  that  host  organisations 
need, over the medium term, to hire a certain (limited) percentage of the trainees it engages17 
would address the problem of young people having to do several traineeships before finding 
regular employment18. Instruments similar to a quality framework already exist within the EU 
–  for  example  in  Italy  and  the  UK.  Given  that  a  code  would  be  voluntary,  the  compliance 
burden of such a measure seems acceptable. Although these principles seem to have general 
validity,  they  should  be  adapted  to  the  type  of  occupation/sector  and  reflect  the  size  of  the 
host organization. 

A  Commission  proposal  for  a  quality  framework  for  traineeships  is  an  option  with  a  wide 
coverage  and  high  direct  visibility.  It  would  engage  the  national  level  in  subscribing  to  the 
quality  principles  –  either  legally  binding  in  form  of  a  Directive  or  in  form  of  non-binding 
recommendations. The actors on the ground will understand that the quality framework is the 
reference  benchmark  for  assessing  the  quality  of  each  individual  traineeship.  A  common 
traineeship quality framework also provides guidance to Member States, Social Partners and 
training institutions for setting up or revising their provisions on traineeships, and to promote 
transnational  mobility  in  traineeships.  In  addition,  a  common  quality  framework  for 
traineeships  could  include  a  partnership  approach  among  employers,  public  employment 
services,  other  public  authorities  and  educational  and  training  institutions  to  better  exploit 
synergies, reduce costs, share best practices etc. 

Overall, a reasonable improvement on the quality and  transparency  of traineeships could be 
expected  in  the  medium  term  from  a  quality  framework  endorsed  at  European  and  national 
level. A limitation of successive traineeships, if properly implemented, could be effective in 
limiting  replacement  risk.  Furthermore,  the  compulsory  registration  of  traineeships  would 
allow having better statistics about traineeships.  

Cons:  Regarding  the  impact  on  the  availability  of  traineeship  places,  this  option  would 
include a certain risk, as inherent in all regulatory solution, that some employers will refrain 
in  the  future  from  providing  traineeship  places,  most  likely  because  they  realise  that  the 
traineeship  places  they  offered  so  far  were  not  of  good  quality.  They  might  consider  that 
certain elements of the quality framework (in particular ensuring mentorship) would result in 
a  too  high  cost  for  the  traineeships.  This  potential  negative  impact  –  given  the  manageable 
implementation costs – however appears limited, and in any case may be offset by an increase 
of good quality traineeships (as clear conditions on what is expected in terms of traineeship 
quality  may  encourage  employers  to  improve  their  offer).  Most  of  the  costs  of  this  option 
would have to be borne by host organisations. 

17 

18 

The rationale for this being that, normally, the offer of high quality traineeships is linked at least partly 
with the intention to hire some trainees in the future, whereas exploitative situations are characterised 
by a repetition of traineeships under the guise of future hopes of employment which never materialise.  
In parallel, an obligation to sign an agreement with the trainee and register it with the labour office or a 
similar  authority  might  be  considered.  Given  the  enforcement  difficulties  identified  by  the  literature, 
registration  might  allow  monitoring  adherence  to  the  rules  and  ensure  respect  of  social  security 
coverage and similar provisions. It might also help improve the data situation on traineeships. Such a 
measure could be introduced either by agreements between social partners or through legislation. 

EN 

40 

   EN 

 
                                                 
Compliance  costs  would  mainly  be  related  to  ensuring  a  proper  learning  content.  Host 
organisations  that  already  provide  learning  content  would  merely  need  to  give  it  the 
appropriate level of formality by listing learning objectives and some other key characteristics 
of the traineeship on paper. Setting up a traineeship agreement should not require more than a 
few hours and the work done could largely be recycled for future trainees. Furthermore, most 
organisations  offering  high  quality  traineeships  already  now  include  such  elements  in  their 
business practice. While compliance costs may affect SMEs to a greater degree, the UEAPME 
response to the Commission's public consultation – in line with the priorities identified in the 
2012-2014  work  programme  of  the  European  social  partners  -  stated  that  a  traineeship 
agreement, agreed learning objectives, the recognition of the traineeship and a limited length 
of the internship are useful elements, and can be agreed also by small businesses. Hence the 
risk  of  reduction  of  traineeships  offered  can  be  considerably  limited  given  the  limited 
additional workload for compliant businesses.  

An  important  question,  however,  remains  the  effectiveness  of  the  impact  on  bad  quality 
traineeships  as  regulatory  solutions  may  work  least  in  Member  States  with  weaker 
enforcement mechanisms, which may be exactly those where there is most need. The quality 
framework for traineeships is a proportionate EU level action that can contribute to achieving 
the intended objective, especially if not in the form of binding legislation.  

Table 9. Foreseeable impact of a European Quality Framework for traineeships 

Measure 
Action 

/ 

Potential 
Impact 
quality 
traineeship 

on 
of 

Voluntary 
(V)  /  Soft 
law  (SL)  / 
Regulator
y  solution 
(R) 

on 
for 

Impact 
demand 
traineeships 
positions (D – 
domestic 
– 
CB  –  cross-
border) 

on 

Impact 
compliance 
costs 
for 
businesses  = 
on 
impact 
of 
supply 
traineeship 
positions 

Flexible 
solution 

Impact 
on 
complian
ce 
costs 
for SMEs 

4  Quality 
framework 
for 
traineeships 
(QFT), 

4b  QFT  for 
long,  cross-
border 
traineeships 

(R) 

++/+++ 

D: ++ 

0/(-) 

-/-- 

Fairly 

CB: ++/+++ 

(R) 

+/++ 

D: + 

0/(-) 

-/-- 

Fairly 

CB: ++/+++ 

Key:  
0 : zero or negligible impact 
(+) / (-) : slight positive (negative) but uncertain impact 
+ / -: possible positive/ negative impact 
++ / -- : likely positive/ negative impact 
+++/--- : very likely positive/ negative impact 

8.5. 

Combination of options 

The above presented measures and elements of EU action could be combined together.  

EN 

41 

   EN 

 
8.6. 

Final overview 

The following table summarises the avenues for action presented above in terms of possible 
impacts and compliance costs.  

Table 10. Overview of impact 

Measure 
Action 

/ 

Potential 
Impact  on 
of 
quality 
traineeship  

Voluntary 
(V)/Soft 
law 
(SL)/Regu
latory 
solution ® 

on 
for 

Impact 
demand 
traineeships 
positions (D – 
domestic 
– 
CB  –  cross-
border) 

on 

Impact 
compliance 
for 
costs 
businesses  = 
on 
impact 
of 
supply 
traineeship 
positions 

Flexible 
solution 

Impact 
on 
complian
ce 
costs 
for SMEs 

na 

0 

Information 
website 
trainees 

for 

D: 0 

CB: + 

Quality label   V/SL 

0/+ 

D: + 

CB: ++ 

0 

0 

0 

0 

Yes 

Fairly 

Quality  label 
+ 
remuneration 

Quality 
framework 
for 
traineeships 
(QFT), 

for 

QFT 
long, 
crossborder 
traineeships 

V/SL 

0/+ 

D: + 

0/(-) 

0(-) 

Fairly 

CB: ++/+++ 

(R) 

++/+++ 

D: ++ 

0/(-) 

-/-- 

Fairly 

CB: ++/+++ 

(R) 

+/++ 

D: ++ 

0/(-) 

-/-- 

Fairly 

CB: ++/+++ 

Key:  
0 : zero or negligible impact 
(+) / (-) :slight positive (negative) but uncertain impact 
+ / -: possible positive/ negative impact 
++ / -- : likely positive/ negative impact 
+++/--- : very likely positive/ negative impact 

9. 

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European Commission (2012b), ESF support to lifelong learning. . Luxembourg: Publications 
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Hommerich,  C.  «Japanese  “  Furītā  ”  and  German  “Generation  Internship”:  The  “precarious 
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empirical study. The Accounting Review, LXII(4), 799-807. 

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McCaffery, J. Perceptions of Satisfaction-Dissatisfaction in the Internship Experience. Public 
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10. 

ANNEXES 

10.1.  Annex I – Apprenticeships vs. Traineeships 

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10.2.  Annex II – Traineeship study, Executive summary 

Introduction 

The main objective of this study was to provide an overview of traineeship arrangements in 
all 27 Member States and to collect the most up-to-date information about different forms of 
traineeships  across  the  EU.  Traineeships  are  seen  as  an  effective  mechanism  which  allows 
young  people  to  familiarise  themselves  with  the  world  of  work,  thus  facilitating  their 
transition from education (or a period of inactivity or unemployment) to employment. 

However,  there  are  also  growing  concerns  across  the  EU  about  the  quality  and  fairness  of 
traineeships as well as their effectiveness as a school-to-work transition mechanism. 

The availability and quality of information on traineeships is rather uneven across the EU.  

This study is a response to the need for a comprehensive EU-wide robust traineeshiprelated 
evidence  base.  It  was  conducted  by  a  consortium  involving  the  Institute  of  Employment 
Studies (IES, UK) as the lead co-ordinator, the Istituto per la Ricerca Sociale (IRS, Italy) and 
the Bundesinstitut für Berufsbildung (BIBB, Germany) as key partners as well as a network of 
regional and national experts. 

The study’s methodological  approach  combined a range of qualitative methodologies which 
included stakeholder interviews at both EU and national levels; a quasi-systematic literature 
review;  a  comparative  mapping  exercise  based  on  information  collected  in  each  Member 
State; and case studies. For the purposes of this study the following five types of traineeships 
were examined: 

•  Traineeships which form optional or compulsory part of academic and/or vocational 

curricula (i.e. traineeships during education); 

•  Traineeships in the open market which, after completion of studies, provide graduates 

with work-related experience before they find stable employment; 

•  Traineeships as part of active labour market policies (ALMPs) for unemployed young 

people with the explicit aim to facilitate their labour market transition; 

•  Traineeships which form part of mandatory professional training, e.g. law, medicine, 

teaching, architecture, accounting, etc.; and 

•  Transnational traineeships. 

Key Findings of the Study 

This section presents a summary of the study’s key findings and recommendations.  

Increased  Policy  Focus  on  Traineeships  as  Mechanisms  which  facilitate  Young  People’s 
Labour Market Entry 

The  dramatic  rise  in  youth  unemployment  and  employment  precariousness  combined  with 
considerable  skill  mismatches  have  prompted  Governments  across  the  EU  to  increasingly 
focus  on  traineeships  as  effective  school-to-work  transition  mechanisms.  As  a  result, 
traineeships  are  increasingly  integrated  into  ALMPs  and/or  form  an  integral  part  of 
educational courses. In view of the proliferation of traineeships undertaken by young people 
in the open market, Member States have also sought to raise the quantity and quality of such 
traineeships  through  either  well-structured  programmes  and/or  regulations  or  voluntary 
quality charters aimed at providing some protection to trainees. 

Funding of Traineeships 

Across  Member  States  the  most  common  methods  of  financing  the  various  types  of 
traineeships  include  European  and  national/regional  funds;  institutional  assistance,  e.g. 

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47 

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university  grants;  personal  financing;  and  company  resources.  Where  public  funding  is 
available,  this  often  involves  considerable  support  from  European  funds,  notably  the 
European  Social  Fund  (ESF).  Personal  financing  is  particularly  common  in  open  market 
traineeships  where,  in  many  cases,  trainees  receive  no  or  insufficient  compensation.  As  a 
result, they have to rely on other funding sources such own savings and family support. 

Lack of a Common Definition of Traineeships 

There  is  a  great  discrepancy  across  all  Europe  in  the  extent  to  which  traineeships  and/or 
trainees  are  clearly  defined.  In  relation  to  the  definition  of  traineeships,  in  most  Member 
States  there  is  either  a  legal  definition  or,  at  least,  a  common  national  understanding  of  the 
concept  of  a  traineeship.  In  general,  in  almost  all  countries  where  a  common  definition  of 
traineeship  exists,  there  is  a  strong  link  between  education  and  work  experience.  Across 
Member  States  the  common  defining  characteristics  of  legal  frameworks  relating  to 
traineeships  are:  (i)  the  general  educational  purpose;  (ii)  the  practical  element  of  learning; 
and (iii) the temporary character of the traineeship. 

Plurality of Regulatory Frameworks for Traineeships 

Across  Europe  there  is  a  plurality  and  variety  of  legislation  and  regulations  governing 
traineeships. This legislative/regulatory diversity exists not only between Member States, but 
also between the different types of traineeships themselves. This, in turn, reflects the fact that 
the concept of traineeship itself is very diverse. Traineeships related to education/training and 
ALMPs tend to be the most regulated, while open market traineeships are subject to much less 
regulation. 

Traineeship-related  legislation  can  be  found  in  laws  and  regulations  associated  with  either 
education and training policies or employment policies, including ALMPs. It usually seeks to 
define and regulate traineeships, the trainee status and associated terms and conditions. Some 
Member  States  seek  to  regulate  directly  traineeships-related  issues  (e.g.  by  Laws  which 
explicitly apply to traineeships). Traineeships which form part of academic study curricula are 
typically  regulated,  organised  and  overseen  independently  and  autonomously  by  the 
educational institution itself. 

It  should  be  noted  that  legislative  and  regulatory  frameworks  do  not  necessarily 
guarantee the quality of traineeships. Rather, it is the implementation of regulations and 
the  robust  monitoring  of  the  entire  process  which  play  a  key  role  in  ensuring  quality 
traineeships. There is particular concern about the inadequacy of regulations for traineeships 
in the open market. 

Great Diversity of Traineeships 

Between and within Member States the study identified a wide range of traineeships: 

•  Traineeships  linked  to  educational  programmes:  Across  the  EU  it  has  become 
increasingly  common  for  traineeships  to  be  integrated  into  curriculum  requirements  for 
both higher vocational and academic education qualifications. Although traineeships have 
been more common in upper secondary and higher vocational education and training, they 
are  now  becoming  an  integral  part  of  academic  curricula  in  most  Member  States.  The 
proportion  of  students  undertaking  traineeships  or  work  placements  as  part  of  higher 
education studies varies widely across Member States, from 87 per cent in the Netherlands 
to 22 per cent in Italy.19

19 

Brennan,  J.  Patel,  K.,  and  Tang,  W.,  (2009).  Diversity  in  the  Student  Learning  Experience  and  Time 
devoted to Study: A Comparative Analysis of the UK and European Evidence, Report to HEFCE by the 
Centre for Higher Education Research and Information, The Open University, April 

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•  Traineeships  in  the  open  market:  In  recent  years  there  has  been  an  expansion  of 
traineeships which young people undertake after graduation, not least because employers 
increasingly  put  a  premium  on  them  having  acquired  work  experience  through  such 
placements.  These  traineeships  have  attracted  most  criticism  since  they  tend  to  be 
unregulated and associated with reports of questionable employer practices including low 
quality, poor terms and conditions, including low or no pay, etc. 

•  Traineeships linked to ALMPs: These are aimed at unemployed young people, typically 
with  no  or  a  low  level  of  skills.  However,  in  recent  years,  especially  since  the  Great 
Recession, traineeship programmes have expanded to include work placements offered to 
graduates with the aim of facilitating their labour market transition. 

•  Traineeships as part of mandatory professional training: Across Member States there 
are  certain  professions  where  there  is  a  legal  requirement  to  undertake  a  compulsory 
law, 
traineeship  as  part  of  mandatory  professional 
education/teaching,  architecture,  etc.  These  traineeships  are  typically  a  pre-requisite  for 
licence to practice and tend to be both well-defined and tightly regulated. However, issues 
of trainee exploitation can emerge due to incorrect implementation of regulations. 

training,  e.g.  medicine, 

•  Transnational  traineeships:  Across  all  Member  States  there  is  evidence  of  growing 
popularity  of  transnational  work-related  mobility.  EU  mobility  programmes,  notably  the 
Leonardo da Vinci and Erasmus programmes, have increased the number of transnational 
work placements across most Member States. A growing number of countries are actively 
promoting  traineeships  abroad,  either  through  EU  or  other  international  youth  mobility 
programmes such as AIESEC and IAESTE as well as through national initiatives. 

Sectors where Traineeships are more common 

The type, range and profile of sectors where traineeships are more prevalent differ, to some 
extent,  according  to  the  specific  type  of  traineeships.  In  certain  sectors  traineeships  are  a 
compulsory part of mandatory professional training (see previous section). In addition, there 
are  a  number  of  sectors  where  traineeships  are  increasingly  common,  including  the  creative 
industries,  media/journalism,  the  public  sector,  third  sector/NGOs,  hospitality,  business 
administration  and  financial  services.  Some  of  these  sectors  such  as  the  creative  industries, 
media/journalism  and  the  third  sector/NGOs  have  also  been  associated  with  questionable 
employer practices. The latter include low or poor learning content; poor working conditions; 
inadequate compensation; using trainees as substitutes for regular staff; repeatedly renewing 
traineeship contracts without offering a permanent position etc. 

Great Variety of Trainee’s Terms and Conditions 

The trainee’s rights, terms and conditions vary considerably both between different types of 
traineeship  and  Member  States.  For  example,  traineeships  linked  to  study  curricula  and 
mandatory professional training have more clearly defined terms and conditions as opposed to 
those in the open market. The issue of trainees’ terms and conditions has increasingly become 
the focus of lively political debate across the EU. As a result, a number of Member States 
with the aim of improving the trainee’s terms and conditions have introduced or are in 
legislative/regulatory  measures  and/or  quality 
the  process  of  developing  new 
frameworks. 

Growing Emphasis on Quality Assurance 

In  a  number  of  Member  States  and  for  certain  types  of  traineeships  the  study  identified 
widespread concerns about the quality of traineeships. A number of countries have actively 
sought  to  improve  this  quality  by  strengthening  quality  assurance  mechanisms.  These 
include  traineeship-related  legislation  (e.g.  the  2011  Cherpion  Law  in  France)  as  well  as 

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specific  quality  frameworks  either  regulated  by  public  institutions  (e.g.  educational 
establishments,  public  employment  services  etc.)  or  developed  by  the  social  partners,  or 
promoted  on  a  voluntary  basis  by  employer  associations,  professional  bodies  and  even 
governments (e.g. the 2011 Common Best Practice Code for High Quality Internships in the 
UK). Quality assurance standards may be compulsory or voluntary. 

Effectiveness of Traineeships 

Across  the  EU  there  is  a  growing  awareness  of  the  benefits  of  traineeships  in  terms  of 
facilitating  the  school-to-work  transition.  However,  there  is  an  uneven  and  rather  patchy 
body  of  evaluation  literature  on  the  effectiveness  of  traineeships.  The  available  literature 
appears to indicate the most effective traineeships are those undertaken during education 
and, in some instances, those linked to well-structured ALMPs. The main success factors of 
these traineeships seem to be i) their strong links with the labour market; ii) a well-structured 
approach; iii) active engagement of stakeholders, including employers; and iv) robust quality 
assurance mechanisms. 

Recommendations 

This  study  has  highlighted  a  number  of  traineeship-related  areas  where  further  action  is 
required either at EU and/or national levels. 

•  There is a need for a clear definition of traineeships at EU level. Given the great variety 
of  traineeships,  this  definition  may  outline  the  key  aims  and  features  of  these  schemes, 
while leaving some space for the specificities of particular types. 

•  There  should  be  more  support  to  include  traineeships  as  a  part  of  study  curricula, 
where possible traineeships should take place during studies and not after graduation. 
•  A concerted effort should be made at both EU and national levels to increase the supply 

of traineeships, especially in SMEs. 

•  There is a need for a Quality Framework for Traineeships offering clear and practical 

guidelines about high quality traineeships. 

•  There  is  a  need  for  some  financial  support  to  trainees,  especially  those  from  less 

privileged backgrounds. 

•  Steps  should  be  taken  to  encourage  open  and  transparent  recruitment  processes  for 

traineeships. 

•  There is a need for more robust data on and evaluation of all types of traineeships at 
both national and EU levels. This includes both quantitative and qualitative data which 
can be used for assessing the quantity, quality, impact and effectiveness of traineeships. 

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10.3.  Annex III – Regulatory Framework 

Source: Traineeship study, European Commission (2012a)

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10.4.  Annex IV – A voluntary approach to Quality Labels for Traineeships 

In  response  to  concerns  about  traineeship  qualities,  in  the  UK  a  number  of  initiatives  have 
been taken by professional associations, stressing voluntary adherence to codes of conduct by 
host  organisations,  particularly  regarding  open  market  traineeships.  This  type  of  traineeship 
has  been  subject  in  the  UK  to  no  or  the  least  regulation  and  little  by  way  of  formal  quality 
assurance processes. There has been an number of voluntary quality charters and frameworks 
aimed  at  providing  good  practice  guidelines  to  organisations  which  take  on  trainees.  Two 
have had a particularly high profile.  

• 

In 2009 the UK’s Chartered Institute for Personnel and Development (CIPD) produced an 
Internship Charter aimed at promoting quality traineeships.  

•  More  recently,  on  18  July  2011,  a  consortium  of  60  professional  associations  launched, 
with  the  support  of  the  UK  Government,  a  voluntary  Code  of  Best  Practice  for  Quality 
Internships  as  a  way  of  addressing  concerns  about  such  schemes,  including  those 
associated with mandatory professional training. Although the Code of Best Practice for 
Quality  Internships  touches  on  trainee  remuneration,  it  does  not  include  it  as  part  of  its 
best  practice  principles.  Instead,  it  exhorts  employers  to  comply  with  the  law  whereby 
trainees,  unless  classified  as  volunteers,  are  entitled  to  NMW,  and  mentions  that  higher 
pay might attract higher calibre candidates to traineeships.  

Both the Internship Charter and the more recent Code are entirely voluntary and have no legal 
force.  

The  Code  recommendations  cover  similar  quality  elements  as  those  identified  by  the 
Traineeship  study,  such  as  a  written  traineeship  agreement  and  a  specification  of  the  nature 
and content of the tasks.  

■ Preparation – Firms need to think beforehand about the effective use of the trainee 

■  Recruitment  –  Recruitment  practices  for  trainees  should  be  the  same  as  those  for  regular 
employees. Traineeship adverts should clearly state the trainee’s roles and responsibilities as 
well as pay, duration and working hours 

■ Induction – All trainees should have a formal induction to the company 

■ Treatment – Trainees should be treated the same as regular employees, integrated into the 
organisation and given meaningful work 

■  Supervision  and  mentoring  –  There  should  be  a  supervisor  with  ring-fenced  time  in  their 
schedule to work with the trainee. The supervisor should establish performance and learning 
objectives, conduct performance reviews and provide feedback 

■ Certification, reference and feedback – Trainees should receive a certificate/reference letter 
and have opportunity to feedback to the organisation on their experience. 

Source: 
best-practice-code-for-quality-internships.pdf 

http://www.bis.gov.uk/assets/BISCore/higher-education/docs/C/11-1068-common-

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10.5.  Annex V – Sectoral distribution of traineeships by country 

Source: Traineeship study, European Commission (2012a) 

10.6.  Annex VI - Market failure in traineeships 

Structural differences in benefits from employment and traineeship contracts…. 

In a regular employment contract, the benefit each party obtains from the arrangement is, to a 
large extent, clear and measurable. In exchange for his or her work effort, the worker receives 
a known amount of pay. The pay is fixed in advance and the work effort can be monitored by 
the employer.  

To be sure, there are other elements of mutual benefit that are less concrete and measurable, 
but may yet form part of either side’s expectations from the contract: for example, the worker 
may expect a pay raise in the future, or the firm may expect a well-treated worker to spread 
some  good  words  about  the  company.  But  in  any  case  these  are  accessory  elements,  which 
would not fundamentally alter the balance of the relationship if they did not materialize. 

The situation is radically different in a traineeship contract. Here, the main benefits accruing 
to the two parties are not so much pay and effort but a set of other benefits (see Chart 1).  

The main benefits of the traineeship for the host organisation are: 

1. 
The possibility to assess precisely the value and productivity of the trainee in case it 
should want to hire a worker ("screening" benefit); this is often the main reason for offering a 
traineeship  position.  The  value  of  this  information  depends  on  many  factors,  such  as  the 

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difficulty  in  selecting  a  good  employee,  the  costs  of  training  and  dismissing  a  bad  one,  the 
share of good candidates in the job pool etc. 

The opportunity to maintain a reputation as a good employer or, more broadly, a good 
immediate  hiring  need  (‘Corporate  Social 

2. 
organisation,  even 
Responsibility’). This is an element of the corporate strategy. 

it  may  have  no 

if 

The value of the work carried out by the trainee. This can be estimated quite precisely 

3. 
by the HO on the basis of the trainee’s qualification and experience. 

The main benefits for the trainee are the following: 

A greater chance of being offered a job at the end of the traineeship compared to an 
1. 
unknown candidate, and the possibility of assessing precisely working conditions in the event; 

2. 
The  value of the practical on-the-job training received, which comes at a cost to the 
host  organisation,  in  the  form  of  time  dedicated  to  form  trainees  by  qualified  employees  or 
trainers; 

The  strengthening  of  one’s  job  prospects  with  other  firms,  consequent  to  having 

3. 
completed a traineeship and having thus gained a higher productivity. 

4. 

Compensation, if any 

The traineeship agreement  will  be concluded if both sides consider that the respective costs 
are in balance with the benefits. 

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Figure 1. Schematic representation of bilateral benefits in employment and traineeship 

arrangements 

Advertising (reputation, CSR) ...

FIRM

Work

Pay

WORKER

Chances of promotion

Screening

Advertising (reputation, CSR) ...

Work

Hiring chances

Training

Compensation

TRAINEE

HOST
ORGANISATION

…create room for market failure 

In a normal traineeship, work and pay, taken in isolation, play a less important role than in a 
regular  employment  contract.  Trainees’  lack  of  experience  translates  into  low  productivity 
and  correspondingly  low  compensation,  if  any  is  paid  at  all.  Hence  the  rationale  and 
advantage  of  the  contract  derives  much  more  from  the  anticipated  value  of  the  other,  less 
tangible, benefits.  

This  situation  creates  room  for  market  failure. In a traineeship,  particularly the  value of the 
benefits  accruing  to  the  trainee  is  uncertain  and  difficult  to  assess  in  advance  (‘information 
asymmetry’).  The  trainee  has  little  possibility  of  realistically  assessing  his  or  her  chance  of 
being hired at the end of the traineeship, or even whether the host organisation intends to hire 
at all. Equally difficult is assessing in advance the value of the job training to be received and 
the consequent strengthening of prospects with other firms. This makes it possible for the host 
organisation  to  underdeliver  on  the  quality  of  training,  i.e.  on  the  job  content  and  on  the 
general conditions of work.  

Trainees cannot screen the quality of the traineeship on the basis of whether the traineeship is 
paid  or  unpaid.  Although  low  quality  is  more  common  in  unpaid  traineeships,  high-quality 
unpaid traineeships exist, particularly in case of technical professions with high training costs 
or  where  a  large  imbalance  between  candidates  and  available  positions  encourages  host 
organisations to minimize compensation.  

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Once the traineeship has begun, the scope for trainees to lobby effectively for improving the 
quality of the traineeship, if it is deficient, is very limited. Trainees may initially put up with 
the situation in the hope that it could improve later. They may be reluctant to complain out of 
fear  of  compromising  their  employment  prospects;  and  they  have  difficulty  referring  to 
quality  standards  because  these  often  do  not  exist.  They  also  face  a  cost  in  changing 
companies and the duration of the traineeship is not very long anyway. 

As a result, trainees are often ‘trapped’ into completing a bad quality traineeship. This will at 
any rate give them some kind of positive outcome (i.e. a mention on their CV) compared to no 
benefit at all if they abandon the traineeship. 

Not only trainees, but also other companies will have difficulty screening ex post the quality 
of a previous traineeship followed by a job candidate. This also contributes to market failure. 

As a result, the traineeship market is characterized by an equilibrium in which a certain share 
of traineeships is low quality. This is in line with survey results, outlined in Box 1, showing 
consistently that a share of traineeships of 20-40% is of insufficient quality.  

Conditions for market failure to occur  

Intentional under-delivery of training or imposition of harsher working conditions can occur if 
the host organisation has no intention to hire and does not care too much about its reputation, 
as otherwise its behaviour would undermine the attainment of those objectives. Such a ‘free-
riding’  host  organisation  will  have  an  incentive  to  limit  its  training  costs  to  the  absolute 
minimum, in order to maximize its profits. For this reason the risk of bad quality is greatest on 
open market traineeships, as there is no external control on training quality.  

The  market  will  always  offer  some  high-quality  traineeships,  because  even  in  a  deep 
recession,  some  organisations  always  have  hiring  needs.  However,  this  share  is  likely  to  be 
lowest now, because the crisis has affected hiring plans negatively; this reduces the incentives 
for  offering  a  high  quality  traineeship.  It  may  also  reduce  the  attachment  of  Ho  to  adhere 
strictly to CSR principles. 

Consequences of market failure 

Cost  minimization  (or  profit  maximization)  by  free  riders  explain  both  types  of  problems 
identified  by  the  studies,  i.e.  limited  learning  content  and  bad  working  conditions,  as  free 
riders  will  both  want  to  minimize  the  training  costs  and  will  also  tend  to  ‘push’  trainees  to 
supply  the  maximum  possible  output.  In  practical  terms,  low-quality  traineeships  will  be 
characterized by very limited. 

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10.7.  ANNEX  VII  –  Comparison  of  the  quality  elements  considered  by  the 
Commission  with  the  Code  of  Best  Practice  (UK),  the  Loi  Cherpion  (FR)  and 
the European Quality Charter on Internships and Apprenticeships presented by 
European NGOs 

Commission considerations 

Code 
Best 
of 
Practice  for  Quality 
Internships  

Loi Cherpion  

Traineeship agreement 

to 

need 

be 
Objectives 
learning  content 
clarified, 
and monitoring (mentorship), 
as  well  as  evaluation  to  be 
ensured. 
final 
certificate/reference  letter  is 
to be given to the trainee. 

A 

Duration  –  no  longer  than  6 
months (with exceptions). 

Induction training and 
meaningful  work  to 
be 
provided; 
supervisor  with  ring-
fenced 
time  should 
establish performance 
learning 
and 
objectives, 
conduct 
performance  reviews 
and provide feedback. 
should 
Trainees 
receive 
a 
certificate/reference 
have 
letter 
to 
opportunity 
feedback 
the 
organisation  on  their 
experience. 

and 

to 

Compulsory 
traineeship 
contract  

for  all  types  of 
traineeships 

Learning  content 
of the traineeship 
to  be  of  high 
quality 
and 
closely  linked  to 
trainee’s 
the 
and/or 
studies 
training 
and 
professional 
development 

activities; 

the 
traineeship 
should 
be 
recognized 
as 
the 
of 
part 
probation  period 
if  the  trainee  is 
recruited 

within  3  months 
upon 
its 
completion; 

trainees 
should 
not  be  assigned 
tasks  performed 
by regular staff. 

Max 6 month per 
academic year. 

European 
Quality  Charter 
on 
Internships 
(for open market 
traineeships) 

Traineeship 
contract  outlining 
the 
length, 
remuneration, 
learning 
and tasks. 

content 

of 

Internships  to  be 
carried  out  under 
a 
guidance 
and 
supervisor 
have  access 
to 
robust  evaluative 
and 

complaints 
channels 
to 
monitor  progress 
and quality of the 

internship;  mid-
term 
final 
and 
evaluation 
needed, as well as 
the  possibility  to 
be hired. 

Length 
of 
internship  should 
be  restricted  to  a 

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Limitation 
traineeships 

of 

successive 

Remuneration/compensation 
to  be  clarified  in  contract 
(recommended  if  there  is  a 
mutual benefit) 

is 
Remuneration 
and 
recommended 
to  be  clarified 
has 
already 
the 
in 
advertisement. 

Social  security  provisions  to 
be clarified in contract. 

protection 
Social 
is 
coverage 
and 
recommended, 
to  be  clarified 
has 
already 
the 
in 
advertisement. 

companies 
should wait for a 
period 
corresponding 

the 
the 

to  1/3  of 
length  of 
previous 
traineeship 
before  taking  on 
a  new  trainee  in 
the same role. 

a 

Trainees 
undertaking 
traineeship 
lasting  for  more 
than  two  months 
should 
receive 
minimum 
compensation  in 
the  form  of  a 
bonus. 

reasonable 
and 
fixed  number  of 
months. 

Use of internships 
should  be  limited 
to pupils, students 
and  very  recent 
graduates;  limited 
number  of  interns 
per 
internship 
provider; 

Decent 
remuneration  not 
the  EU 
below 
line  of 
poverty 
median 
60% 
income 
or 
national minimum 
wage  (whichever 
favourable). 

the 
Inclusion  of 
in 
the 
intern 
security 
social 
system,  especially 
those  of  health, 
unemployment, 
pension systems. 

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