COMMISSION STAFF WORKING DOCUMENT Applying the Quality Framework for Traineeships Accompanying the document Communication from the Commission to the European Parliament, the European Council, the Council, the European Economic and Social Committee and the Committee of the Regions The Youth Guarantee and the Youth Employment Initiative three years on
Date: 2016-10-04
Institutions: Directorate-General for Employment, Social Affairs and Inclusion, European Commission
Subjects: EU Member State, EU employment policy, EU initiative, education, integration into employment, job access, vocational training, young worker, youth employment, youth unemployment

EN 

   EN 

   EUROPEAN COMMISSION  Strasbourg, 4.10.2016  SWD(2016) 324 final   COMMISSION STAFF WORKING DOCUMENT Applying the Quality Framework for Traineeships Accompanying the document Communication from the Commission to the European Parliament, the European Council, the Council, the European Economic and Social Committee and the Committee of the Regions The Youth Guarantee and the Youth Employment Initiative three years on {COM(2016) 646 final} {SWD(2016) 323 final}  
 
 
Applying the Quality Framework for Traineeships 

Contents 
1. Introduction ............................................................................................................................ 3 

2. Scope of the Council Recommendation ................................................................................. 4 

Table 1: Main differences between open market and ALMP-type traineeships ................ 5 

3. Implementation measures for the QFT ................................................................................... 5 

3.1. State of play of regulatory frameworks ........................................................................... 5 

Table 2: Overview of regulatory frameworks on traineeships in the EU-28, 2016 ........... 6 

3.2. New legislation introduced by Member States since 2014 ............................................. 6 

Table 3: Legal changes since 2014 relevant to compliance with the QFT in the EU-28 .. 7 

3.3. Involvement of social partners ........................................................................................ 8 

4. Compliance of Member States' legislation with the QFT ...................................................... 9 

Table 4. Compliance of open market traineeships with QFT dimensions in the EU-28 .. 10 

Table 5. Compliance of ALMP-type traineeships with the QFT dimensions in the EU-28 
Member States .................................................................................................................. 11 

4.1. Conclusion of a written traineeship agreement (Points 2-3) ......................................... 11 

4.2. Learning and training objectives (Points 4-5) ............................................................... 12 

4.3. Working conditions applicable to trainees (Points 6-8) ................................................ 12 

4.4. Reasonable duration (Points 10-12) .............................................................................. 13 

4.5. Proper recognition of traineeships (Point 13) ............................................................... 14 

4.6. Transparency requirements (Points 14-15) ................................................................... 14 

4.7. Cross border traineeships (Points 16-17) ...................................................................... 15 

5. Use of European Structural and Investment Funds (Point 18) ............................................. 15 

6. Commission support to QFT implementation (Points 23-28) .............................................. 16 

7. Summary and remaining challenges .................................................................................... 18 

Annex I: Country Fiches .......................................................................................................... 19 

2 

 
 
 
 
 
1. Introduction 

Traineeships  are  becoming  increasingly  common  for  young  people  during  or  after  their 
studies, as  they can  help them to  gain relevant experience and find a foothold in the labour 
market.  A  Eurobarometer  survey  on traineeships1  in  2013  showed  that  almost  every second 
young person in the age group 18-35 had at least one traineeship experience. 7 out of 10 ex-
trainees stated that their traineeship experience was useful in finding a regular job. 

Several studies2 confirmed the effectiveness of traineeships in enhancing trainees’ chances of 
securing  a  job.  This  is  particularly  true  for  traineeships  within  active  labour  market  policy 
(ALMP)  measures:  participants  in  ALMP-type  traineeships  find  regular  employment  more 
easily and in a shorter time span than non-participants. 

Increasingly,  however,  a  range  of  stakeholders  have  voiced  concerns  about  the  quality  of 
traineeships. Various studies and surveys3 confirmed these concerns, particularly with regard 
to insufficient learning content and substandard working conditions. 

As  a  European  response  to  these  concerns,  the  Commission  proposed  a  Council 
Recommendation on a Quality Framework for Traineeships (QFT), preceded by a two-stage 
social  partner  consultation  that  did  not  result  in  a  social  partner  agreement.4  The  Council 
Recommendation  was  adopted  by  the  Employment,  Social  Policy,  Health  and  Consumer 
Affairs  Council  (EPSCO)  in  March  2014.5  It  makes  recommendations  on  the  quality  of 
traineeships  in  terms  of  learning  content,  working  conditions,  and  transparency  regarding 
financial conditions and hiring practices. The Recommendation contains 22 quality elements 
that are directly transposable into national legislation or social partner agreements. 

The  QFT  is  particularly  relevant  as  a  reference  for  quality  offers  of  traineeships  under  the 
Youth Guarantee, since many national Youth Guarantee schemes foresee traineeships as one 
of the four types of offers6 for young people. 
This  Staff  Working  Document  (SWD)  analyses  how  Member  States’  existing  and  new 
legislation and social partner agreements comply with the requirements of the QFT and points 
to  remaining  challenges.  It  does  not,  however,  assess  the  extent  to  which  legislation  and 
agreements  are  respected.  Compliance  of  national  legislation  with  EU  law  covering 
traineeships is monitored on an ongoing basis. 
The SWD is based on  

  Member States’ replies to a Commission questionnaire submitted by the end of 2015 

 

(as per point 20 of the Council Recommendation);  
the  independent  assessment  of  experts  of  the  European  Employment  Policy 
Observatory (EEPO) network about each Member State;  

  a  synthesis  report  by  ICF  International  on  the  Implementation  of  the  2014  Council 

Recommendation on a Quality Framework for Traineeships (April 2016).7  

1 Eurobarometer 378: http://ec.europa.eu/public_opinion/flash/fl_378_en.pdf; according to the survey 46 % of the 
respondents had at least one traineeship experience. 
2 I.a. Apprenticeship and Traineeship schemes in EU 27: Key success factors. A guidebook for policy planners and 
practitioners. European Commission / Ecorys 2013. 
3 I.a. Interns Revealed, European Youth Forum, 2011; Eurobarometer on traineeships, 2013. 
4 While European Social Partners could not agree on launching negotiations on a possible QFT agreement under Article 154 
TFEU, they included traineeships in their 2013 Framework of Actions on Youth Employment. 
5 Council Recommendation on a Quality Framework for Traineeships (2014/C 88/01); OJ C 88, 27.3.2014, p. 1-4. 
6 The four types of offer are: employment, continuous education, an apprenticeship or a traineeship. 
7 None of these reports was published. 

3 

 
 
 
                                                 
The SWD also builds on a strategic dialogue with civil society (including the European Youth 
Forum)  on  29  January  2016  and  on  an  exchange  with  social  partners  during  the 
17 February 2016 Social Dialogue Committee. 

In  the  forthcoming  sections  the  SWD  outlines  the  scope  of  the  Council  Recommendation 
(Section 2); presents the overall implementation measures for the QFT (Section 3); provides 
an assessment of compliance of each key quality criteria set by the QFT (Section 4); presents 
the  use  of  European  Structural  and  Investment  Funds  for  traineeships  (Section  5);  presents 
Commission  support  to  the  implementation  of  the  QFT  (Section  6);  and  finally  considers 
remaining challenges (Section 7). 

2. Scope of the Council Recommendation 

The QFT has a limited scope, as it only covers two main types of traineeships: those available 
on  the  open  market,  as  well  as  those  that  are  part  of  ALMP  programmes.  It  does  not  cover 
traineeships  that  are  part  of  the  curricula  of  formal  education  or  vocational  education  and 
training (VET), neither does it cover traineeships whose completion is mandatory in order to 
access a specific profession (e.g. teaching, medicine, architecture, etc.). The reason for this is 
that traineeships which belong to these categories are in general of better quality, due to the 
quality assurance by the educational institutions or professional organisations involved. 

In the case of open market traineeships there is no third party involved further to the trainee 
and  the  host  organisation,  which  also  means  that  the  quality  assurance  of  the  traineeship 
becomes  more  difficult.  ALMP-type  traineeships,  on  the  other  hand,  are  offered  to  (young) 
unemployed or those at risk of becoming unemployed, and there is usually a public institution 
(most often a PES) acting as an intermediary between the host organisation and the trainee. 
This  intermediary institution  also  has  a  supervising  function  in  terms  of  traineeship  quality. 
Table 1 below summarises the main differences between these two types of traineeships. 

4 

 
 
 
 
 
 
 
Table 1: Main differences between open market and ALMP-type traineeships 

Aspect 

Open market traineeships 

ALMP-type traineeships 

Responsibility for 
organising traineeships 

Employers (public/private/non-profit) 

Public Employment Services (PES) in cooperation with 
employers 

Type of agreement 

Agreement between trainee and employer  Tripartite trainee–employer–PES agreement 

Contract 

Usually with a form of work contract 

With or without work contract 

Remuneration 

Paid by employer (basic wage) or unpaid  Trainees  may  receive  allowance  or  compensation  and/or 

Subsidies 

No state subsidies to employers 

Aim 

Preparing for regular employment  

Beneficiaries 

Students, graduates or new employees in 
need of specific practical training on the 
job 

Source: European Commission based on ICF analysis. 

other benefits (i.e. as unemployed) 

Employers may receive wage subsidies from state or EU 
funds to cover the labour costs incurred by trainees 

Easing transition from school to work or from inactivity 
to activity 

Unemployed and inactive young people/adults 

3. Implementation measures for the QFT 

3.1. State of play of regulatory frameworks 

All  28  Member  States  have  regulatory  frameworks  that  cover  at  least  some  form  of 
traineeships outside of educational curricula. Of the 28, eight have specific  legal regulations 
on both ALMP-type and open market traineeships.8 

All Member States have some form of regulation on ALMP-type traineeships. In comparison, 
open market traineeships are generally less regulated and only to varying extents across the 
EU.  In  some  Member  States9  such  traineeships  —  involving  a  direct  agreement  between 
employer  and  trainee  —  are  not  allowed  by  law.  Moreover,  in  a  number  of  other  Member 
States,10  traineeships  in  the  open  market  —  although  legally  possible  —  are  reported  to  be 
very rare or nearly non-existent. In the majority of Member States open market traineeships 
are either not regulated, or are subject to general labour law provisions. 

Table 2 below presents an overview of the forms of regulation on both types of traineeships in 
the EU-28. 

8 BE, LT and SI adopted an overarching regulatory framework on traineeships, which applies to both open market and 
ALMP-type traineeships. BG, DE, ES, PL and PT have specific legal regulations on both types of traineeships, though they 
are separate. 
9 FR, IT, LV. 
10 CY, HR, MT. 

5 

 
 
 
 
 
 
 
 
 
                                                 
Table 2: Overview of regulatory frameworks on traineeships in the EU-28, 2016 

Form of regulatory 
framework 

Overarching law 

Specific legal act on 
traineeships 

Specific provisions in labour 
law/ALMP acts 

Open market traineeships 

ALMP-type traineeships 

ES, PL, PT 

BE, LT, SI 

ES, IT, PL, PT, RO, SE, EL (only some 
traineeship schemes) 

BG, DE, RO, LU 

BG, DK, DE, EE, HR, HU, MT, SK, FI 

Subject to general labour law  AT, CZ, IE, EL, HU, NL, FI 

LV, CY, CZ 

Specific to the ALMP 
programme (no legal act) 

Collective agreements 

AT, SI, FI, SE  

No regulation 

DK, EE, SK, SE, UK; 
for some forms of traineeships: AT, 
EL, HU 

Source: ICF analysis based on EEPO experts’ reports. 

IE, FR, NL, AT, UK, LU, EL (most 
ALMP-type traineeships) 

We can distinguish three main categories of countries within the EU: 

  MS with regulatory frameworks (overarching laws or specific legal acts) concerning 

both types of traineeships: BE, BG, DE, ES, LT, PL, PT, RO, SI. 

  MS with a regulatory framework on one type of traineeship: DK, EE, HR, IT, MT, SK, 

FI, SE. 

  MS with weak regulatory frameworks (only specific ALMP programmes or some 

general provisions in labour law): AT, CZ, IE, EL, FR, CY, LV, LU, HU, NL, UK. 

3.2. New legislation introduced by Member States since 2014 

Eight Member States11 have undertaken legal changes to strengthen the alignment of national 
frameworks  with  the  Council  Recommendation  since its adoption  in  2014,  and  six  Member 
States reported that further legislation on traineeship quality is being planned.12 Most of the 
reforms concern limiting the duration of traineeships to six months, clarifying conditions for 
longer traineeships and assigning mentors to provide guidance and supervise progress during 
the traineeship. 

In the other half of EU countries no significant legal changes were introduced in response to 
the Council Recommendation and no further legislation or social partner agreements are being 
planned.  Some  of  these  Member  States  claim  that  pre-existing  legislation  already  complies 
with the QFT principles,13 at least to some degree; others report that there are no (or very few) 
open market traineeships, while ALMP-type traineeships mostly comply with QFT standards 
already.14 

11 BG, DE, EL, ES, FR, LT, PT, SE. 
12 EE, ES, LV, LT, PL, SI. Although no legislation is in the pipeline yet, BE, HR and CY have intentions or broad plans 
towards further regulating traineeships in line with the QFT. 
13 E.g. DK, IT, RO. 
14 E.g. CY, FI, HR, HU, MT. 

6 

 
 
 
 
 
 
 
 
 
 
                                                 
Although  not  targeting  traineeships  specifically,  some  Member  States15  also  adopted  new 
reforms, such as amendments to labour laws or ALMP reforms, which had an influence on the 
traineeship systems. 

Table 3 below, gives an overview of recent legal changes adopted in the EU-28 in line with 
the QFT. 

Table 3: Legal changes since 2014 relevant to compliance with the QFT in the EU-28 

Country  New legislation passed  Existing laws adapted  Laws planned or in the 

BE 

BG 

CZ 

DE 

DK 

EE 

EL 

ES 

FI 

FR 

HU 

HR 

IE 

IT 

CY 

LT 

LU 

LV 

MT 

NL 

AT 

PL 

PT 

RO 

SE 

SI 

SK 

UK 

N 

N 

N 

Y 

N 

N 

Y 

Y 

N 

Y 

N 

N 

N 

N 

N 

Y 

N 

N 

N 

N 

N 

N* 

Y 

N 

N 

N 

N 

N 

N* 

Y 

N 

N 

N 

N 

N 

Y 

N 

N 

N 

N 

N 

N 

N 

Y 

N 

N* 

N 

N 

N 

N 

Y 

N 

Y 

N 

N* 

N 

pipeline 

Y 

N* 

N 

N 

N 

Y 

N 

Y 

N 

N 

N 

N 

N 

N 

N 

Y 

N 

Y 

N 

N 

N 

Y 

N 

N 

N 

N* 

N 

N 

Social partner 
agreements (existing 
and planned) 

N 

N 

N 

N 

N 

N 

N 

Y 

N 

N 

N 

N 

N 

N 

N 

N 

Y 

N 

N 

N 

N 

N 

N 

N 

N 

Y 

N 

N 

Source: ICF analysis based on EEPO experts’ reports. 
* Some changes in legislation were reported but not linked to the ensuring of compliance with the QFT 

In  addition  to  the  above,  recent  —  although  pre-QFT-  traineeship  legislation  in  Italy16  and 
Romania17 also complies to a large extent with the QFT (the Italian framework even served as 

15 BE, BG, DK, DE, HR, IT, HU, MT, NL, AT, PL, SE. 

7 

 
 
 
 
 
                                                 
a model for the Commission proposal at the time). Furthermore, while the UK officially does 
not intend to implement the QFT, there has been a Code of Best Practices elaborated in 2011 
with the aim to ensure high quality internships. This Code is promoted among others by the 
UK government. 

3.3. Involvement of social partners 

Only a few Member States18 reported having significantly involved social partners in drafting 
new legislation or having concluded social partner agreements on the topic of traineeships. In 
some  other  Member  States  social  partners  have  been  involved  in  monitoring  the  quality  of 
traineeships,  or  the  promotion  of  traineeships.19  In  the  majority  of  EU  countries,  there  has 
been only very limited or no cooperation with social partners in terms of making traineeships 
compatible  with  the  QFT.  It  can  thus  be  considered  that  point  21  (promotion  of  active 
involvement of social partners in applying the QFT) has been implemented only to a limited 
extent. 

In  Luxembourg,  the  government  is  in  negotiations  with  social  partners  to  set  up  a  new 
traineeship  framework  in  line  with  the  QFT.  However,  as  of  May  2016  it  is  not  known 
whether  the  existing  framework  regarding  traineeships  will  indeed  be altered  in  the  light  of 
the QFT or not. 

In  Slovenia,  provision  of  paid  traineeships  is  one  of  the  goals  set  in  the  new  Social 
Agreement  for  2015-2016,  signed  by  social  partners  in  February  2015.  However,  it  is  not 
clear what specific changes this would imply and how they would match the QFT. The trade 
unions are more active in the area of traineeships than employers’ associations; for example, 
in  2012  one  of  the  Slovenian  trade  union  confederations  proposed  the  introduction  of 
compulsory traineeships for young people. 

In Spain, a new Agreement for Employment and Collective Bargaining for 2015-2017 (ANC 
2015-2017)  was  signed  in  June  2015  by  the  social  partners.  According  to  the  agreement, 
social partners will prioritise labour traineeships (with work contracts). 

Although  there  are  no  social  partner  agreements  with  a  specific  focus  on  traineeships  in 
Denmark, local unions are involved in monitoring that traineeships and employment with a 
wage subsidy do not crowd out ordinary jobs. 

Bulgarian social partners reported about their contribution to the development of a new type 
of traineeship contract. 

16 Law 92/2012. 
17 Law 335/2013. 
18 ES, LU, SI. 
19 E.g. in CY and PT. 

8 

 
 
 
 
 
 
 
 
 
 
 
                                                                                                                                                         
Actions by EU level social partners 

At  the  level  of  the  EU  social  partners  a  Framework  of  Actions  on  Youth  Employment  (non-binding 
guidelines) was negotiated in 2012-2013. The latest (second) follow-up report on the Framework of Actions 
(September 2015) includes national actions and best practices from 21 EU MS linked to the four priorities 
identified  in  the  Framework  of  Actions:  learning,  transition,  employment  and  entrepreneurship.  Among 
these best practices some relate to the promotion of traineeship programmes (e.g. CY and PT), while in the 
case of BG social partners report about their contribution to the development of a new type of traineeship 
contract. 

Social partners in a number of sectors (Chemical Industry, Commerce, Construction, Education, Electricity, 
Personal  Services,  Postal  Services,  Road  Transport,  and  Telecommunication)  have  also  reached  joint 
positions on  skills  incl.  with  specific  actions  on  traineeships  and pledges  on  apprenticeships  to  raise  their 
availability and improve their quality. 

http://ec.europa.eu/social/main.jsp?catId=521&langId=en&agreementId=5471  

4. Compliance of Member States’ legislation with the QFT 

This  section  provides  information  on  how  Member  States’  legislation  complies  with  key 
quality criteria set within the QFT: 

  Conclusion of a written traineeship agreement 
  Learning and training objectives 
  Working conditions applicable to trainees 
  Reasonable duration 
  Proper recognition of traineeships 
  Transparency requirements 

These are the quality criteria considered to be elementary in order to ensure that a traineeship 
is  of  sufficiently  high  quality  in  terms  of  learning  content,  working  conditions  and 
transparency.20  In  addition  to  the  above  criteria,  this  section  also  examines  how  national 
legislations comply with the QFT points related to cross-border traineeships. 

It is important to note that due to the differences in the level of legislation of open market and 
ALMP-type traineeships, while open market traineeships comply with individual QFT criteria 
only in a few Member States, ALMP-type traineeships are fully or mostly compliant with the 
individual QFT criteria in most Member States. 

Table 4 below presents an overview of compliance of open market traineeships with the QFT 
dimensions  in  the  28  Member  States  of  the  EU.  Table  5  presents  the  same  for  ALMP  type 
traineeships. 

20 This section focuses on the assessment of these criteria. Points 9 (rights and obligations) and 22 (involvement of PES, 
educational institutions and training providers) are not assessed in this SWD, as they are not of direct relevance to the quality 
of traineeships. A brief analysis of the use of European Structural and Investment Funds (point 18) can be found in Section 5. 
Point 19 (applying the QFT as soon as possible) is assessed throughout the present SWD. Point 20 (provide information to 
the Commission) is assessed in Section 6 of the SWD. Point 21 (social partner involvement) was assessed in Section 3. 

9 

 
 
 
 
 
 
 
 
                                                 
 
 
 
 
Table 4. Compliance of open market traineeships with QFT dimensions in the EU-28 

Source: European Commission based on ICF analysis 

Legend: 

Green — Fully/mostly compliant 

Yellow — Partly compliant 

Red — Non-compliant 

Orange — Modest/minimal compliance overall 

N/A — This type of traineeship is either illegal, very rare or nearly non-existent and there is no information available on 
conditions and thus on QFT compliance 

10 

QFT dimensions ATBEBGCYCZDEDKEEELESFIFRHRHUIEITLTLULVMTNLPLPTROSESISKUKNFNNNFNFNN/AN/ANNN/ANNPNN/ANNFFFNFNPNN/AN/AFNNPNNNNNNNN/AN/ANNFNPFFNNFFFNFNFFFNPFNN/AN/AN/AN/AN/AN/AN/AN/ANPNFNFFNFFPNN/AN/ANNFNFFFFNNPNPFFNFNN/AFPNFFNPPNNN/AN/AFFN/APN/AN/ANFFNNFNFNN/ANFFFFPNFNFNNNNNNFNN/AN/ANNN/AFFNNFPNN/AFNNN/ANN/AN/AN/AN/APFNN/APPFFFNNNNPNFNNFFFFFFFFNFFNNFFNFFNNNNNNFNFFNFFNPFNN/ANNNNNFNNN/ANNFFFNNFNPNNFNNFNPN/ANNPNNNN/AFPN/AFFFNFNPFNFFNNNFFFFNN/AFNPFFPNFNPNNFNFFNNPN/AN/ANNNNFN/AN/ANPFNNNN/AN/AFNFFNNFNPNFN/AFN/ANN/APN/AN/ANNEmployment services transparent on financial conditions of traineeships FFFCircumstances and conditions of longer traineeships are clarifiedAgreement allows termination by either party with advance noticeProper recognition / attestation of traineeships through a certificateTransparency regarding allowance/compensation  Transparency regarding health and accident insurance Transparency regarding hiring practices in recent yearsRequirement of a written traineeship agreementLearning objectives clarifiedMentor/supervisor assignedAgreement clarifies whether there is health and accident insurance, and sick leaveAgreement clarifies whether there is allowance/ compensation and its amount Duration of a traineeship is limited to 6 monthsFFFFPNNPPNNPPNPPP 
 
 
 
Table 5. Compliance of ALMP-type traineeships with the QFT dimensions in the EU-28 Member States 

Source: European Commission based on ICF analysis 

Legend: 

* Only for specific programmes in CZ, IE, FR, CY, HY, NL, UK 

Green — Fully/mostly compliant 

Yellow — Partly compliant 

Red — Non-compliant 

N/A — There is no information available on conditions and thus on QFT compliance 

4.1. Conclusion of a written traineeship agreement (Points 2-3) 

According  to  the  points  2  and  3  of  the  QFT,  traineeships  should  be  based  on  a  written 
agreement between the trainee and the traineeship  provider. This  agreement should indicate 
the ‘educational objectives, the working conditions, whether an allowance or compensation is 
provided, the duration of the traineeship, the rights and obligations of the trainee and of the 
traineeship  provider,  including  where  relevant,  the  traineeship  provider’s  policies  on 
confidentiality and the ownership of intellectual property rights’. 

In  all  Member  States  there is  some  form  of  written  agreement  for  ALMP-type traineeships. 
However,  this  is  not  always  the  case  for  traineeships  in  the  open  market.  In  seven  Member 
States21 a written agreement is not required by law when the traineeship is concluded between 
the employer and trainee. Even in Member States where a written traineeship agreement is a 
formal requirement, the agreement often does not cover all elements as required by the QFT. 
Most  often 
regarding 
allowance/compensation are missing. 

the  educational  objectives  and  conditions 

information  on 

21 DK, EE, IE, HU, FI, SK, FI, SE. 

11 

QFT dimensions ATBEBGCY*CZ*DEDKEEELESFIFR*HRHU*IE*ITLTLULVMTNL*PLPTROSESISKUK*FFFFFPNNNNNNPPNFFFFFFFFPFFPPFEmployment services transparent on financial conditions of traineeships FFFFNNPPPNNNNNNNPNFFFFFFFFFFFFFFFFFFFFPPFTransparency regarding hiring practices in recent yearsNFTransparency regarding health and accident insurance FFFNNFFFFFFFFFFFPFPFFPTransparency regarding allowance/compensation  FFFNFNFFFNNPFPPNNFFFFFFProper recognition / attestation of traineeships through a certificateFPPFFFFPFFFFFPFFFFFPPAgreement allows termination by either party with advance noticeFFFNFNPFFNFFNNFPNFFFNFFCircumstances and conditions of longer traineeships are clarifiedFPNFFFFFFFNFFPFNNFFFNNFFFFFFPFFFFFNPFNPFFFNFFFFPFFFFPFFFFFFFFPFFFPFFPFFFFFFFNFFPFFFFFFPMentor/supervisor assignedFFFFFFFFFNFFFFFFFFPPLearning objectives clarifiedFPFPFFFFFFFFFFFPPFFFFPFPFFFFRequirement of a written traineeship agreementFFFPFAgreement clarifies whether there is health and accident insurance, and sick leaveFFFFFFFFFFFFFFFFFNFFNFPFFDuration of a traineeship is limited to 6 monthsFFFPFFFNPFPAgreement clarifies whether there is allowance/ compensation and FFFFPPFFFFFFFFFFFNFFFPFFFPF 
 
 
 
 
 
 
                                                 
4.2. Learning and training objectives (Points 4-5) 

The  QFT  indicates  in  its  points  4  and  5  that  learning  objectives  should  be  clarified  in  the 
written  agreement  between  the  trainee  and  the  traineeship  provider.  It  also  invited  Member 
States,  in  point  4,  to  ‘promote  best  practices  as  regards  learning  and training  objectives in 
order to help trainees acquire practical experience and relevant skills; the tasks assigned to 
the trainee should enable these objectives to be attained’. 

While in the case of ALMP-type traineeships 27 Member States comply with point 4,22 only 
10 Member States do require the same for open market traineeships.23  

Point 5 of the QFT invites Member States to encourage traineeship providers to designate a 
supervisor for trainees, thereby guiding the trainee through the assigned tasks, and monitoring 
and  assessing  his/her  progress.  This  quality  aspect  presents  the  biggest  discrepancy  in 
compliance between ALMP-type and open market traineeships across the EU. In the case of 
the former, 25 Member States have in place legislation that requires a mentor or supervisor to 
be assigned to each trainee. This is only the case in seven countries24 regarding traineeships in 
the open market. 

4.3. Working conditions applicable to trainees (Points 6-8) 

Point 6 of the QFT calls on Member States to ensure that the rights and working conditions of 
trainees  are  respected  with  regard  to  applicable  EU  and  national  law,  including  ‘limits  to 
maximum  weekly  working  time,  minimum  daily  and  weekly  rest  periods  and,  where 
applicable,  minimum  holiday  entitlements’.  Point  7  invites  Member  States  to  encourage 
traineeship providers to clarify whether they provide coverage in terms of health and accident 
insurance as well as sick leave. According to point 8 of the QFT, the traineeship agreement 
should clarify whether an allowance or compensation is applicable, as well as its amount.25  

These  points  —  in  particular  6  and  7  —  have  obtained  high  levels  of  compliance  across 
Member  States  for  both  open  market  and  ALMP-type  traineeships.26  High  level  of  de  jure 
compliance in  the case of open  market traineeships  is  due to the fact that in  many  Member 
States  where  there  is  no  (or  weak)  specific  legislation  on  open  market  traineeships, 
traineeships often count as  a labour relationship and therefore general  labour law applies  to 
trainees, just like to workers.27 

22 All but LV. 
23 BE, BG, CZ, DE, ES, LT, NL, RO, SI, UK. 
24 BE, BG, LT, NL, PT, SI, UK. 
25 N.B. the European Commission did not take a stance on whether traineeships should be paid or not, as this does not fall 
within EU competence. Nevertheless, recommendations 14 and 15 on transparency regarding compensation and social 
security coverage, as well as hiring chances aim to equip trainee candidates with the necessary information to be able to make 
well informed choices already at the time of the application. 
26 In the case of open market traineeships only DK, EE, FI, IE, SE and SK do not comply. As for ALMP-type traineeships, all 
Member States comply at least partly, with the exception of LT. 
27 However, the actual enforcement of general labour law provisions as regards trainees was not specifically assessed. 

12 

 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Even in Member States where the traineeship is not considered to be an employment relation 
under national legislation, trainees are often protected by the general rules of health and safety 
at work, and by insurance for work-related accidents and social security provisions.28 

It is important to note in this context that Directive 91/533/EC29 — commonly referred to as 
the Written Statement Directive  — requires employers to inform  their employees in writing 
about the essential aspects of their employment relationship, be it by way of an employment 
contract  or  a  different  kind  of  document  issued  by  the  employer.  The  information  must  be 
provided when the employment starts or up to two months thereafter. 

The Directive is currently subject to a REFIT evaluation by the Commission. The latter also 
looks at the possible coverage of trainees under this Directive. Preliminary results of the legal 
analysis at national level indicate that trainees are always covered by the rules transposing the 
Directive  or  specific  legislation  in  11  Member  States.30  In  the  rest  of  the  Member  States, 
trainees  are  covered  if  they  fall  within  the  definition  of  an  employee,  which  in  most  cases 
includes a requirement that they are remunerated. 

4.4. Reasonable duration (Points 10-12) 

In its point 10 the QFT indicates that Member States should ‘ensure a reasonable duration of 
traineeships  that,  in  principle,  does  not  exceed  six  months,  except  in  cases  where  a  longer 
duration is justified, taking into account national practices’. 

Again,  Member  States  respect  this  principle  more  in  the  case  of  ALMP-type  traineeships, 
where 17 Member States are in full compliance and further 4 Member States comply for most 
types  of  traineeships  (with  allowing  for  some  traineeships  targeted  to  certain  disadvantaged 
groups to be longer). 

For open market traineeships, only four Member States31 set the maximum legal duration of a 
traineeship  to  six  months,  while  in  the  majority  of  Member  States  there  is  either  no  legal 
limitation of duration, or the maximum duration can be longer than 6 months. 

According  to  point  11  of  the  QFT,  the  circumstances  and  conditions  under  which  a 
traineeship may be extended or renewed, after the initial traineeship agreement has expired, 
should be clarified. Such clarifications exist in 15 Member States for ALMP-type traineeships 
and in four more Member States at least for some ALMP measures on traineeships. Only six 
Member States comply with this rule for open market traineeships; however, the high share of 
non-compliance  is  partly  due  to  the  fact  that  in  some  countries  traineeships  cannot  be 
extended. 

The  QFT  (point  12)  invited  Member  States  to  ‘encourage  the  practice  of  specifying  in  the 
traineeship agreement that either the trainee or the traineeship provider may terminate it by 
written communication, providing  advance  notice  of  an  appropriate  duration  in  view  of  the 
length of traineeship and relevant national practice’. 

28 This is the case for ALMP-type traineeships in DK, EE, ES, FR, IE, LT, PT, SE, UK. 
29 Council Directive of 14 October 1991, OJEC, n° L 288/32 of 18.10.91. 
30 BE, BG, CY, DE, ES, FR, HU, PL, PT, RO, SI. 
31 BE, LT, PL, RO. However, it is important to remember that in 6 Member States open market traineeships are either not 
allowed by law or very rare (see in Section 3). 

13 

 
 
 
 
 
 
 
 
 
 
                                                 
This rule is respected in 22 Member States in the case of ALMP-type traineeships (although 
in  5  of  those  while  termination  is  allowed,  it  is  not  necessarily  indicated  in  the  traineeship 
agreement). Similarly, in 16 Member States also open market traineeships comply  with  this 
rule (with four Member States of the 16 not requiring this aspect to figure in the traineeship 
agreement). 

Only in a minority of Member States the conditions for terminating the traineeship are not set 
by law: in six Member States32 in the case of open market traineeships and in five Member 
States33 for ALMP-type traineeships. 

4.5. Proper recognition of traineeships (Point 13) 

The QFT recommends that Member States should ‘promote the recognition and validation of 
the knowledge, skills and competences acquired during traineeships and encourage providers 
to attest them, on the basis of assessment, through a certificate’. 

As  for  ALMP-type  traineeships,  20  MS  comply  at  least  partially  (e.g.  in  some  cases,  the 
employer  issues  a  letter  of  recommendation,  that  does  not  necessarily  cover  all  aspects 
detailed in the QFT recommendation). Only seven MS comply with this rule in terms of open 
market traineeships — this quality aspect has one of the lowest levels of compliance of all the 
QFT criteria. 

4.6. Transparency requirements (Points 14-15) 

Transparency requirements are seen as an innovative element of the QFT: while the QFT does 
not recommend that traineeships are paid under all circumstances, point 14 says that Member 
States  should  ‘encourage  traineeship  providers  to  include  in  their  vacancy  notices 
information  on  the  terms  and  conditions  of  the  traineeship,  in  particular  on  whether  an 
allowance  and/or  compensations  and  health  /accident  insurance  are  applicable  as  well  as 
information on recruitment policies, including the share of trainees recruited in recent years’. 
The objective was to allow trainee candidates the possibility to make a well informed decision 
about  accepting  or  refusing  a  traineeship  offer,  based  on  information  regarding  financial 
conditions and hiring chances. 

Results are rather mixed when it comes to the take up of this point by Member States. While 
it seems to be well accepted for financial and social security conditions,34 take-up is marginal 
in  the  case  of  transparency  on  hiring  chances.  This  QFT  aspect  records  by  far  the  least 
compliance  across  the  EU  for  both  open  market  and  ALMP-type  traineeships.  Only  in  a 
minority of Member States is information regarding hiring practices required to be included in 

32 DK, EE, EL, SK, FI, SE. 
33 CY, EL, ES, IT, FI. 
34 In the case of ALMP-type traineeships all MS comply at least partially, while for open market traineeships all but DK, EE, 
FI, IE, SE and SK. 

14 

 
 
 
 
 
 
 
 
 
 
 
 
                                                 
vacancy notices: this is the case for eight Member States35 for ALMP-type traineeships and 
only two36 for open market traineeships. 

4.7. Cross border traineeships (Points 16-17) 

Points  16  and  17  refer  to  the  facilitation  of  cross-border  traineeships  within  the  EU. 
According  to  point  16  Member  States  should  i.a.  clarify  national  legal  frameworks  for 
traineeships, establish clear rules on hosting and sending trainees, and reduce administrative 
formalities. Point 17 refers to the extension of EURES to (paid) traineeships. 

Following  a  Commission  Implementing  Decision  on  EURES  in  November  2012,37 Member 
States endorsed in 2013 a two-step approach: 1) presentation of information on the EURES 
portal  by  country  on  apprenticeships  and  traineeships  in  general,  in  line  with  point  16 
(country sheets); 2) development within the framework of EURES, of a form of clearance, in 
line  with  point  17  (exchange  of  offers  and  applications  for  traineeships and  apprenticeships 
across borders). 

All Member States have provided country sheets in 2015 that will be translated and published 
by the Commission on the EURES portal by the end of 2016. 

In  the  meantime,  the  EURES  Regulation  has  come  into  force  and  replaced  the  above 
Decision.38  It  introduces  the  obligation  on  Member  States  to  share  EU-wide  data  on  those 
apprenticeships and traineeships subject to an employment relationship within two years after 
the date of its entry into effect (14 May 2018). 

5. Use of European Structural and Investment Funds (Point 18) 

Several Member States have reported on the use of European Structural and Investment Funds 
for ALMP-type traineeship programmes, including with funding from the ESF programming 
period 2007-2013. In particular, a number of ESF-funded projects have been implemented to 
enhance  the  number  and  quality  of  traineeships  for  specific  target  groups39  in  several 
countries.40  

A  significant  share  of  ESF  funds  is  used  to  cover  employers’  costs  related  to  trainees, 
typically in the form of wage subsidies.41 In certain cases (e.g. HR), ESF financing is used to 
put in place support systems for employers to provide mentoring of trainees. 

35 BG, DK, EL, AT, PT, RO, SI, SE. 
36 BG and SI. Another two MS (ES and NL) require some information on recruitment policies, but not necessarily data about 
the share of trainees recruited in recent years. 
37 http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32012D0733. 
38 OJ L107, 22 April 2016, nr 59; http://ec.europa.eu/social/main.jsp?catId=1083&langId=en. 
39 Such as hard-to-place unemployed people, young people unable to find a job in line with their qualification, NEETs, young 
people at risk of social exclusion and young people from marginalised communities, etc. 
40 BG, CZ, EL, ES, HR, HU, PL, PT, RO. 
41 This is the case in BG, ES, HU, RO. 

15 

 
 
 
 
 
 
 
 
 
 
 
 
                                                 
ESF 2014-20 support to training is programmed either in the context of access to employment 
measures or under life-long learning measures. Under the thematic objective for employment, 
which represents 37 % of ESF resources42 and amounts to 30.8 billion EUR, over a third of 
the ESF Operational Programmes have included traineeships as actions to be supported. This 
includes  over  6.3  billion  EUR  of  ESF  resources  specifically  dedicated  to  the  sustainable 
integration of young people into the labour market 

To this the Youth Employment Initiative (YEI) should be added, which provides 6.4 billion of 
targeted funding to young persons not in employment, education or training. Traineeships and 
apprenticeships  represent  a  major  share  of  the  YEI-supported  actions.  Over  70 %  of  the  20 
eligible  Member  States  are  implementing  traineeships  and  apprenticeships  measures.  Some, 
such  as  BE,  CY,  ES,  IT  and  PL  financially  prioritise  the  share  of  traineeships  and 
apprenticeships in comparison to other measures supported by the YEI. Wage subsidies and 
measures  to  reduce  non-wage  labour  costs  are  currently  implemented  with  YEI  support  in 
over half of the Member States. 

The ESF and YEI together will therefore invest at least 12.7 billion EUR over 2014-2020 to 
support youth labour market integration measures. 

6. Commission support to QFT implementation (Points 23-28) 

The last six points of the QFT (Points 23-28) describe what the Commission intends to do to 
support Member States in applying the Council Recommendation. The commitments taken in 
2014 were: 

  Fostering  close  cooperation  with  Member  States,  social  partners  and  other 

stakeholders with a view to swiftly applying the Recommendation; 

  Monitoring the progress in applying the QFT and analysing the impact of policies in 

place; 

  Reporting on progress of QFT implementation; 
  Working with Member States, social partners, employment services, youth and trainee 

organisations and other stakeholders to promote the Recommendation; 

  Encouraging and supporting Member States to make use of ESIF and ERDF and other 

EU funds to increase the number and quality of traineeships; 

  Examining together with Member States the possibility to include paid traineeships in 
EURES,  and  setting  up  a  dedicated  webpage  on  national  legal  frameworks  for 
traineeships. 

Between  the  adoption  of  the  Council  Recommendation  and the  publication  of  this  SWD  on 
QFT implementation, the Commission was following up on all these areas. 

Within  the  project  ‘Providing  targeted  advice  on  ESF  support  to  apprenticeship  and 
traineeship schemes’ (2013-2015) the Commission undertook a series of activities and events 

42 Technical assistance excluded. 

16 

 
 
 
 
 
 
 
 
 
                                                 
targeted to Member States, with a view to strengthen the support of ESF to quality traineeship 
schemes in the new programming period 2014-2020. These activities included:43 

  a review of existing traineeship programmes, 
 

the establishment of a helpdesk to advise Member States (ESF Managing Authorities) 
and other stakeholders (in particular social partners) on how to establish and manage 
apprenticeship and traineeship programmes under ESF 2014-2020, 
training  courses  in  ten  Member  States44  on  launching  and  managing  traineeship 
programmes, 

 

  a conference to identify needs of Member States for technical assistance, 
  a seminar on evaluation and monitoring of traineeship programmes, 
  a dedicated website with a platform for exchange (a shared space), 
 
raising  activities  around 

the  organisation  of  awareness 
apprenticeship) programmes in Member States. 

traineeship 

(and 

In  April  2014  the  Commission  organised  a  workshop  for  the  exchange  of  best  practices 
regarding  high  quality  traineeships.  All  three  multilateral  surveillance  reviews  of  the 
Employment  Committee  on  youth  employment  and  the  implementation  of  the  Youth 
Guarantee  (December  2013,  2014  and  2015)  looked  at  traineeships  as  one  of  the  Youth 
Guarantee offers. The QFT was also a recurrent topic on the agenda of the regular meetings of 
national Youth Guarantee coordinators in 2015 and 2016. 

In  terms  of  cooperation  with  other  stakeholders  (in  particular  employers  and  youth/trainee 
organisations),  the  Commission  jointly  with  CSR  Europe  launched  the  European  Pact  for 
Youth  in  November  2015  to  create  10 000  quality  business-education  partnerships  and  to 
provide  100 000  new,  good-quality  apprenticeships,  traineeships,  or  entry-level  jobs.  Your 
First  EURES  Job  (YfEJ)  and  the  platform  ‘Drop’pin’45  have  also  provided  targeted  support 
for employment and training in a European context. Traineeship opportunities are also a part 
of  the  European  Youth  Portal,46  which  was  restructured  and  re-launched  in  May  2013.  The 
portal is evolving into a platform for young people to engage with policy-makers and to have 
their say on the issues that affect them. 

In  addition,  the  Commission  supported  the  Employers’  Guide  to  Quality  Internships,47 
launched  in  March  2015  by  the  European  Youth  Forum,  together  with  major  businesses. 
Throughout  2014  and  2015  the  Commission  was  also  in  regular  contact  with  youth  and 
trainee NGOs (in particular the European Youth Forum, B!NGO and InternsGoPro). 

Furthermore, as discussed in Section 4, the new EURES Regulation introduces the obligation 
on  Member  States  to  share  EU-wide  data  on  (paid)  traineeships  subject  to  an  employment 
relationship as from 2018. The Commission will publish by the end of 2016 on the EURES 
portal the country sheets provided by Member States.   

In addition, the EU Erasmus+ programme is providing about 1 million opportunities to higher 
education and VET students, apprentices and recent graduates for traineeships abroad during 

43 For more information on the results of the project visit: http://ec.europa.eu/social/main.jsp?catId=1045&langId=en. 
44 BG, CY, EL, ES, IT, LT, LV, MT, PL, RO. For more details visit: 
http://ec.europa.eu/social/main.jsp?langId=en&catId=1045&furtherEvents=yes&limit=no . 
45 https://ec.europa.eu/eures/droppin/en. 
46 http://europa.eu/youth/EU/working/work-and-learn_en . 
47 http://www.youthforum.org/publication/an-employers-guide-to-quality-internships/. 

17 

 
 
 
 
 
 
 
                                                 
the period 2014-2020. One in three students participating in this traineeship scheme is offered 
a job by their host company and one in ten create their own start-up. 

Finally,  the  QFT  became  a  reference  document  for  major  EU  initiatives  such  as  the  Youth 
Guarantee  and  EURES/YfEJ.  The  QFT  sets  the  standards  to  determine  what  can  be 
considered as a quality traineeship offer in these initiatives. This is of particular relevance at a 
time when the quality of offers is at the centre of the debate around the Youth Guarantee. 

7. Summary and remaining challenges 

Half of the Member States have undertaken legal changes that strengthened the alignment of 
national  legal  frameworks  with  the Council  Recommendation  since its adoption  in  2014,  or 
report plans to do so. The extent to which new legislation and social partner agreements are 
respected in practice needs to be seen. 

In  any  case,  there  are  some  further  challenges  to  the  compliance  of  national  legislation  and 
social partner agreement provisions with the QFT: 

  Open market traineeships are much less regulated than ALMP-type traineeships; 
  While working conditions are in general well respected, most countries are affected by 
remaining  gaps  in  traineeship  regulation  or  the  fragmentation  of  the  existing 
frameworks and policies. Major gaps are related to: 

insufficient learning content (in the case of open market traineeships); 
lack of transparency on hiring practices; 

o 
o 
o  possibility of traineeships longer than 6 months; 
o 

lack of rules on proper recognition of traineeships. 

 

In the majority of EU countries, cooperation with social partners in terms of making 
traineeships compatible with the QFT could be improved. 

18 

 
 
 
 
 
 
 
 
 
Annex I: Country Fiches 

19 

 
 
 
 
Country fiche AUSTRIA 

Implementation of the Council Recommendation on a Quality Framework for 
Traineeships (2014/C 88/01) 

General description — open market and ALMP-type traineeships 

Austria  has  not  introduced  any  new  legislation  to  implement  the  Quality  Framework  for 
Traineeships.  There  is  no  relevant  legislation  or  social  partner  agreement  in  the  pipeline 
either. Current legislation complies with QFT only to a limited extent. 

Traineeships can have two main forms of contracts in Austria, depending on whether they are 
training/educational  relationships  or  employment  relationships.  The  decision  on  the 
contractual  form  of  the  specific  traineeship  has  to  be  made  for  each  case  separately. 
Jurisdiction mentions several criteria for an employment relationship, e.g. the embeddedness 
of  trainees  into  the  normal  working  process,  fixed  working  time,  a  workplace  etc.  Most 
traineeships  in  Austria  are  employment  relationships  and  are  thus  subject  to  general  labour 
law, including the applying collective agreement and company agreements. One special form 
of employment related traineeships are those which underlie a freelance contract. This kind of 
traineeships is not or is just partially protected by the labour law. Only the legal requirements 
concerning  the  termination  of  employment  have  to  be  used  within  this  form  of  traineeship. 
Educational related traineeships on the other hand are not regulated by law. 

In  addition  the  Law  against  Wage  and  Social  Dumping  (‘Lohn-  und  Sozialdumping 
Bekämpfungsgesetz — LSDB’), in force since 2011, contains instruments to fight underpaid or 
unpaid  employment  related  traineeships.  In  this  context,  intensified  social  insurance  audits 
were carried out. 

As  of  December  2015,  the  level  of  the  basic  wage  has  to  be  specified  in  the  position 
specification  statement  (Dienstzettel).  This  document  is  required  if  no  work  contract  was 
concluded.  All  employment  related  contracts  are  subject  to  this  regulation.  This  might 
enhance transparency concerning wage or compensation level. 

for  employment 

the  majority)  while  QFT 
In  general, 
recommendations regarding working conditions and transparency on financial conditions are 
well respected, there is no legislation to ensure a high quality learning content of traineeships. 

(which  are 

traineeships 

Remaining challenges 

  No legislation to ensure high quality learning content (learning objectives and 

mentor/supervisor) 

  No transparency of hiring chances 
  Duration can exceed 6 months 
  The use of ‘educational traineeships’ can allow traineeship providers to refrain from 

offering adequate working conditions 

20 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Assessment of open market as well as ALMP-type traineeships in terms of compliance 
with QFT 

Open market traineeships  ALMP-type traineeships 

Written traineeship agreement  
Written traineeship agreement concluded 
Learning and training objectives  
Objectives clarified 
Mentor/supervisor assigned 
Working conditions applicable to trainees  
Health/accident insurance and sick leave clarified 
Allowance/compensation and amount clarified 
Reasonable duration  
Duration limited to 6 months 
Conditions of longer duration clarified 
Termination allowed 
Proper recognition of traineeship  
Proper recognition through certificate 
Transparency requirements  
Allowance/compensation   
Health/accident insurance  
Hiring practices in recent years 
Employment services on financial conditions 

Fully compliant 
Partly compliant 
Not compliant 

21 

 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
 
  
 
  
 
 
 
 
 
 
Country fiche BELGIUM 

Implementation of the Council Recommendation on a Quality Framework for 
Traineeships (2014/C 88/01) 

General description — open market and ALMP-type traineeships 

In Belgium the pre-existing traineeship legislation already complies to a large extent with the 
QFT  (with  the  exception  of  transparency  on  hiring  chances).  Chapter  X,  ‘Conventions 
d’immersion  professionnelle’,  of  the  Title  IV  ‘Emploi’  of  the  Law  Programme  of  2  August 
2002, forms a national framework to be respected by all traineeships. The federal legislation 
defines the most practical part of the traineeship agreement (objectives, working conditions, 
duration,  rights  and  obligations,  transparency).  Nevertheless,  the  Convention  d’immersion 
professionnelle has been transferred to the Regions after the 6th State Reform. 

There has been new legislation introduced since the adoption of the QFT on certain ALMP-
type traineeships in the Brussels region and on dual training in Wallonia (although the latter 
does not fall under the scope of the QFT). These new pieces of legislation comply with QFT 
standards  to  a  large  extent,  but  cover  only  a  small  share  of  traineeships.  In  addition,  the 
Brussels Government is preparing a draft regulatory framework on open market traineeships. 
Wallonia also has plans to update in 2016-17 legislation on the traineeship ‘entrepreneurial 
training’ (stage relative a la formation de chef d’entreprise). Finally, as reported by Flanders, 
the current state reform in Belgium may create additional opportunities to expand the number 
and the quality of the traineeships in accordance with the QFT. 

Remaining challenges 

  All 3 regions: legislation does not cover transparency on hiring chances; 

  Brussels  Capital  Region:  there  is  no  formal  obligation  to  recognise  a  traineeship 

through a certificate. 

22 

 
 
 
 
 
 
 
 
 
 
Assessment of open market as well as ALMP-type traineeships in terms of compliance 
with QFT 

Open market traineeships 

ALMP-type traineeships 

Written traineeship agreement 
Written traineeship agreement concluded 
Learning and training objectives 
Objectives clarified 
Mentor/supervisor assigned 
Working conditions applicable to trainees 
Health/accident insurance and sick leave clarified 
Allowance/compensation and amount clarified 
Reasonable duration 
Duration limited to 6 months 
Conditions of longer duration clarified 
Termination allowed 
Proper recognition of traineeship 
Proper recognition through certificate 
Transparency requirements 
Allowance/compensation   
Health/accident insurance  
Hiring practices in recent years 
Employment services on financial conditions 

B — F — W 

B — F — W 

B — F — W 
B — F — W 

B — F — W 
B — F — W 

B — F — W 
F — W 
B — F — W 

B — F — W 
B — F — W 

B — F — W 
B — F — W 

B — F — W 
F — W 
B — F — W 

F — W 

F — W 

B — F — W 
B — F — W 
B — F — W 
F — W 

B — F — W 
B — F — W 
B — F — W 
F — W 

Fully compliant 
Partly compliant 
Not compliant 

23 

 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
 
  
 
  
 
 
 
 
 
 
Country fiche BULGARIA 

Implementation of the Council Recommendation on a Quality Framework for 
Traineeships (2014/C 88/01) 

General description 

Open market traineeships 

Bulgaria  has  adapted  its  Labour  Code  (LC)  in  2014  in  order  to  comply  with  the  Quality 
Framework  for  Traineeships.48  The  updated  legislation  complies  to  a  large  extent  with  the 
QFT. 

The  new  provisions  introduced  a  traineeship  employment  contract  (TEC)  that  did  not  exist 
beforehand.  Such  contracts  shall  be  signed  only  with  youth  aged  up  to  29  years  with 
secondary  or  higher  education  without  being  employed  and  without  any  professional 
experience on graduated profession or specialty. 

Employment relationships between an employer and a trainee shall be set in a contract signed 
in compliance with the general provisions for labour contracts regulated in the LC. TEC sets 
also  the  terms  and  conditions  for  remuneration  of  the  trainees.  The  amount  of  the 
remuneration shall not be lower than the minimum wage in the country. 

Trainees  are  also  entitled  to  all  rights  of  people  working  under  employment  contracts, 
including  occupational  safety,  trade  union  membership,  collective  bargaining,  etc.  TEC  is  a 
fixed-term contract for a period of no less than six months and no more than 12 months. The 
amendments to the LC provide for a definition of ‘traineeship’ — execution of certain work 
under  mentorship,  which  aims  acquisition  of  practical  skills  on  acquired  profession  or 
specialty by a trainee. TECs (as all labour contracts) have to be registered with the National 
Revenue Agency (NRA) and National Insurance Institute. 

There  are  proposals  for  amendments  to  the  Corporate  Taxation  Law  to  introduce  tax 
alleviations for employers who sign traineeship contracts. However, as of June 2016 specific 
texts have not  been proposed  yet.  Social partner  agreements are not planned  or proposed  in 
this  area.  Traditionally,  employers  are  declaring  a  willingness  to  participate  in  shaping  any 
curricula,  incl.  for  traineeships  outside  of  VET,  but  in  practice  they  are  hardly  joining  the 
process. 

ALMP-type traineeships 

For ALMP-type traineeships the practice is to conclude a general type of fixed-term contract 
with unemployed (Art. 68 para. Item 1 of LC) for the duration of the traineeship. 

Remaining challenges 

  duration of traineeships allowed up to 12 months; 

48 See LC articles 233а, 233b and 233c. 

24 

 
 
 
 
 
 
                                                 
 

legislation does not cover traineeship in non-profit organisations. 

Assessment of open market as well as ALMP-type traineeships in terms of compliance 
with QFT 

Open market traineeships 

ALMP-type traineeships 

BG 
Written traineeship agreement 
Written traineeship agreement concluded 
Learning and training objectives 
Objectives clarified 
Mentor/supervisor assigned 
Working conditions applicable to trainees 
Health/accident insurance and sick leave clarified 
Allowance/compensation and amount clarified 
Reasonable duration 
Duration limited to 6 months 
Conditions of longer duration clarified 
Termination allowed 
Proper recognition of traineeship 
Proper recognition through certificate 
Transparency requirements 
Allowance/compensation   
Health/accident insurance  
Hiring practices in recent years 
Employment services on financial conditions 

Fully compliant 
Partly compliant 
Not compliant 

25 

 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
 
  
 
  
 
 
 
 
 
 
Country fiche CROATIA 

Implementation of the Council Recommendation on a Quality Framework for 
Traineeships (2014/C 88/01) 

General description — ALMP-type traineeships 

Croatia  has  not  introduced  any  new  legislation  to  implement  the  Quality  Framework  for 
Traineeships.  There  is  no  relevant  legislation  or  social  partner  agreement  in  the  pipeline 
either. 

Given that in Croatia open market traineeships virtually do not exist (other than traineeships 
mandatory for access to specific professions), this fiche summarises QFT compliance of the 
ALMP  measure ‘Occupational training  without  commencing employment’  (a form of work-
placed training). Traineeships within this programme only partly comply with the QFT. 

The Croatian government envisages the development of further training schemes and forms of 
work-based  learning.  Planned  activities  also  include  the  development  of  shorter-term 
measures aimed at the development of on-the-job trainings to comply more with the needs of 
individuals who are particularly vulnerable, such as persons with disabilities and Roma, and 
to provide them with the opportunity to present their skills to potential employers. In addition, 
development of support to employers  has been envisaged, primarily to enable them to build 
quality  mentorships.  Criteria  for  mentorships  and  quality  work-based  learning  will  be 
developed  and  necessary  support  will  be  ensured  for  mentors  and  educational  organisations 
(financial,  organisational,  etc.),  capacities  of  employers  for  quality  traineeships  will  be 
assessed, and the possibility of using an ‘outsourced’ mentor will be tested at the employers 
who do not have the possibility to organise their own mentors. 

Although  significant  development  of  the  traineeship  system  in  Croatia  has  been  envisaged, 
the  emphasis  has  been  put  primarily  on  the  traineeships  within  the  education  system,  while 
open market traineeships have not been considered in more comprehensive scope. 

Remaining challenges 

  No obligation to clearly define learning objectives 
  Duration is from 12 to 36 months 
  no obligation of employers to properly validate the knowledge, skills and competences 

acquired during the traineeship 

26 

 
 
 
 
 
 
 
 
 
 
 
 
 
Assessment of open market as well as ALMP-type traineeships in terms of compliance 
with QFT 

Open market traineeships 

ALMP-type 
traineeships 

n.a. 

Written traineeship agreement 
Written traineeship agreement concluded 
Learning and training objectives 
Objectives clarified 
Mentor/supervisor assigned 
Working conditions applicable to trainees 
Health/accident insurance and sick leave clarified 
Allowance/compensation and amount clarified 
Reasonable duration 
Duration limited to 6 months 
Conditions of longer duration clarified 
Termination allowed 
Proper recognition of traineeship 
Proper recognition through certificate 
Transparency requirements 
Allowance/compensation   
Health/accident insurance  
Hiring practices in recent years 
Employment services on financial conditions 

Fully compliant 
Partly compliant 
Not compliant 

27 

 
 
 
 
 
 
 
  
  
  
  
  
 
  
 
  
  
  
 
  
 
  
  
  
 
  
 
  
 
  
  
  
 
  
  
  
 
  
 
  
 
  
 
  
 
 
 
 
 
 
 
  
 
  
 
  
 
 
 
 
 
 
Country fiche CYPRUS 

Implementation of the Council Recommendation on a Quality Framework for 
Traineeships (2014/C 88/01) 

General description 

There  is  no  overarching  legal  framework  for  traineeships  in  Cyprus.  Traineeships  within 
ALMP  programmes  generally  comply  with  QFT,  while  open  market  traineeships  are  not 
regulated at all — although they are not too frequent either. 

Recently an effort for regulating all kinds of traineeships offered in Cyprus has been initiated 
by  competent  authorities.  It  is  not  clear  how  far  preliminary  efforts  in  this  direction  have 
progressed.  Given  that  for  the  last  three  years  the  political  and  economic  priorities  of  the 
government  were  overwhelmed  by  the  crisis  and  the  need  to  implement  Memorandum  of 
Understanding provisions; it may not give the QFT top priority. 

ALMP-type traineeships 

The two programmes offered by the Human Resource Development Authority (HRDA) and 
aimed  at  providing  job  placement  opportunities  for  the  acquisition  of  work  experience  for 
young  unemployed  secondary  graduates  and  young  unemployed  degree  holders  entail  very 
clear  job  placement  and  training  provisions  and  follow  QFT  recommendations  2-22  very 
closely. 

Remaining challenges 

  Lack of regulation regarding open market traineeships 
  Termination with advance notice not allowed for ALMP-type traineeships 
  No transparency regarding hiring practices in the case of ALMP-type traineeships 

28 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Assessment of open market as well as ALMP-type traineeships in terms of compliance 
with QFT 

Open market traineeships 

ALMP-type traineeships 

Written traineeship agreement 
Written traineeship agreement concluded 
Learning and training objectives 
Objectives clarified 
Mentor/supervisor assigned 
Working conditions applicable to trainees 
Health/accident insurance and sick leave clarified 
Allowance/compensation and amount clarified 
Reasonable duration 
Duration limited to 6 months 
Conditions of longer duration clarified 
Termination allowed 
Proper recognition of traineeship 
Proper recognition through certificate 
Transparency requirements 
Allowance/compensation   
Health/accident insurance  
Hiring practices in recent years 
Employment services on financial conditions 

Fully compliant 
Partly compliant 
Not compliant 

29 

 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
 
  
 
  
 
 
 
 
 
 
 
Country fiche CZECH REPUBLIC 

Implementation of the Council Recommendation on a Quality Framework for 
Traineeships (2014/C 88/01) 

General description 

The  Czech  Republic  has  not  introduced  any  new  legislation  to  implement  the  Quality 
Framework for Traineeships. There is no relevant legislation in the pipeline, and no specific 
cooperation  is  foreseen  with  the  social  partners  to  make  traineeships  QFT  compatible. 
Existing legislation only partly complies with the QFT. 

Open market traineeships 

Companies  frequently  employ  interns  using  the  ‘agreement  on  work’,  a  general  type  of 
contract  stipulated  by  the  Labour  Code.  Although  contracts  for  traineeships  contain  a  job 
description, this is in general rather vague and hardly sets any learning objectives. There are 
no quality checks to monitor whether an intern is acquiring ‘practical experience and relevant 
skills’ as there is no supervisory body outside the employers. The ‘agreement on work’ does 
not require the intern to have a mentor. Duration can exceed 6 months. There is no certificate 
after the traineeship, in general a letter of recommendation is provided. 

Open market traineeships are QFT compatible to the extent that there is a written traineeship 
agreement, and that rights, obligations and working conditions are governed by the common 
rules of the labour law. 

ALMP-type traineeships 

ESF  funded  traineeship  programmes  (e.g.  the  ‘Traineeships  in  companies’49  under  the  OP 
Education  and  Competitiveness  2007-13)  are  much  more  aligned  to  the  QFT  stipulations. 
Trainees  within  these  ALMP  programmes  are  assisted  by  a  trained  mentor,  and 
learning/training goals are set. Most ALMP-type traineeships take place in small and medium 
sized  firms  because  administrative  costs  savings  are  more  notable  there,  while  larger 
employers prefer offering open market traineeships through the ‘agreements on work’. 

Remaining challenges 
Existing legislation for open market traineeships complies only to a limited extent with the 
QFT regarding 

  Learning content (clarification of objectives and assignment of mentor) 
  Duration (not limited to 6 months) 
  Recognition of traineeships 
  Transparency regarding hiring practices 

49 Evaluation of the project: http://www.narodnikatalogstazi.cz/images/NKS/SvF_evaluacni_zprava.pdf. 

30 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Assessment of open market as well as ALMP-type traineeships in terms of compliance 
with QFT 

Open market traineeships 

ALMP-type 
traineeships 

Written traineeship agreement 
Written traineeship agreement concluded 
Learning and training objectives 
Objectives clarified 
Mentor/supervisor assigned 
Working conditions applicable to trainees 
Health/accident insurance and sick leave clarified 
Allowance/compensation and amount clarified 
Reasonable duration 
Duration limited to 6 months 
Conditions of longer duration clarified 
Termination allowed 
Proper recognition of traineeship 
Proper recognition through certificate 
Transparency requirements 
Allowance/compensation   
Health/accident insurance  
Hiring practices in recent years 
Employment services on financial conditions 

Fully compliant 
Partly compliant 
Not compliant 

31 

 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
 
  
 
  
 
 
 
 
 
 
Country fiche DENMARK 

Implementation of the Council Recommendation on a Quality Framework for 
Traineeships (2014/C 88/01) 

General description 

Denmark has not introduced new legislation in response to the Council Recommendation and 
no  further  legislation  or  social  partner  agreements  are  in  the  pipeline.  Current  legislation 
barely complies with QFT for open market traineeships; nevertheless, the level of compliance 
is relatively high for ALMP-type traineeships. 

Open market traineeships 

Open  market  traineeships  in  Denmark  are  considered  a  ‘grey  area’  without  specific 
legislation.  They  are  mostly  unpaid  and  serve  as  a  stepping  stone  after  graduation  to  paid 
employment  —  typically  within  the  creative  sectors  like  film-making,  journalism  and 
advertising. From time to time these informal traineeships are debated in the media.50 

Even these traineeships comply partly with QFT standards in terms of working conditions, as 
employers  have  an  obligation  to  cover  all  employees,  paid  and  unpaid,  with  an  insurance 
towards  work  related  accidents.  The  unpaid  voluntary  trainees  will  also  be  covered  by  the 
legislation concerning the working environment. 

ALMP-type traineeships 

Since 2003 unpaid traineeships with private or public employers have been an integral part of 
Danish  active  labour  market  policy.  During  the  traineeship  the  trainee  receives  the  normal 
benefit that he/she is eligible for (unemployment insurance benefit or cash benefits). 

A  balance  has  to  be  kept  between  the  number  of  ordinary  employees  and  the  number  of 
trainees  (maximum  one  trainee  for  five  employees  for  workplaces  with  less  than  50 
employees and a maximum one for ten for workplaces with more than 50 employees). 

These short traineeships (max 3 months) comply well with QFT criteria, with the exception of 
a proper recognition through a certificate and transparency regarding hiring chances. 

Remaining challenges 

lack of legislation regarding open market traineeships; 

 
  no proper recognition of ALMP-type traineeships; 
 

lack of transparency of hiring chances in the case of ALMP-type traineeships. 

50 Se for instance http://www.information.dk/276394. 

32 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Assessment of open market as well as ALMP-type traineeships in terms of compliance 
with QFT 

Open market 
traineeships 

ALMP-type traineeships 

Written traineeship agreement 
Written traineeship agreement concluded 
Learning and training objectives 
Objectives clarified 
Mentor/supervisor assigned 
Working conditions applicable to trainees 
Health/accident insurance and sick leave clarified 
Allowance/compensation and amount clarified 
Reasonable duration 
Duration limited to 6 months 
Conditions of longer duration clarified 
Termination allowed 
Proper recognition of traineeship 
Proper recognition through certificate 
Transparency requirements 
Allowance/compensation   
Health/accident insurance  
Hiring practices in recent years 
Employment services on financial conditions 

Fully compliant 
Partly compliant 
Not compliant 

33 

 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
 
  
 
  
 
 
 
 
 
 
Country fiche ESTONIA 

Implementation of the Council Recommendation on a Quality Framework for 
Traineeships (2014/C 88/01) 

General description 
In  Estonia  there  have  been  no  legislative  changes  following  the  adoption  of  the  QFT,  apart 
from  some  developments  in  traineeships  within  the  formal  education  system.  There  are  no 
relevant  social  partner  agreements,  although  social  partners  are  in  the PES  governing  board 
and are involved in the adoption process of employment programmes. 

Open market traineeships 

Open  market  traineeships  —  which  are  most  often  offered  to  students,  but  are  outside  the 
formal education curricula and therefore not controlled by the educational institution  — are 
not regulated in Estonia. The only relevant legislation entered into force on 1 July 2014: since 
then Estonian legislation requires any person working (or doing any activities, including as a 
trainee) in the premises of the employer to be registered at the Tax and Customs Board. This 
also includes the case where there is no salary/wage provided — in this case work has to be 
registered as volunteering. 

ALMP-type traineeships 

Conditions for ALMP measures are regulated by Labour Market Services and Benefits Act, 
which  has  not  seen  any  changes  since  2014.  Some  changes  are  planned  in  the  new 
Unemployment  Insurance  and  Labour  Market  Services  Act,  which  is  still  waiting  to  be 
discussed in the Parliament. 

The regulations for ALMP type traineeships largely comply with the QFT recommendations, 
with  the  exception  of  the  proper  recognition  of  the  traineeship  and  transparency  regarding 
hiring chances. As for the former, a recent evaluation study already recommended to the PES 
to enhance the recognition of traineeships through a system of attestation. 

Remaining challenges 

  No legislation covering open market traineeships; 
  No transparency regarding hiring practices in recent years (ALMP-type traineeships); 
  No proper recognition of ALMP-type traineeships. 

34 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Assessment of open market as well as ALMP-type traineeships in terms of compliance 
with QFT 

Open market traineeships 

ALMP-type 
traineeships 

Written traineeship agreement 
Written traineeship agreement concluded 
Learning and training objectives 
Objectives clarified 
Mentor/supervisor assigned 
Working conditions applicable to trainees 
Health/accident insurance and sick leave clarified 
Allowance/compensation and amount clarified 
Reasonable duration 
Duration limited to 6 months 
Conditions of longer duration clarified 
Termination allowed 
Proper recognition of traineeship 
Proper recognition through certificate 
Transparency requirements 
Allowance/compensation   
Health/accident insurance  
Hiring practices in recent years 
Employment services on financial conditions 

Fully compliant 
Partly compliant 
Not compliant 

35 

 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
 
  
 
  
 
 
 
Country fiche FINLAND 

Implementation of the Council Recommendation on a Quality Framework for 
Traineeships (2014/C 88/01) 

General description 

Finland has not introduced new legislation in response to the Council recommendation and no 
further legislation or social partner agreements are in the pipeline. 

Open market traineeships 

In Finland almost all the traineeships belong to education curricula and are therefore outside 
the scope of the QFT recommendation. The very few open market traineeships are based on 
an  employment  relationship  and  the  relevant  provisions  of  the  labour  law  and  collective 
agreements are applicable. 

ALMP-type traineeships 

ALMP-type  traineeships  —  in  particular  within  the  programme  ‘Work  experiment’  that 
provides the traineeship offers under the Finnish Youth Guarantee — comply to a reasonable 
extent with the QFT. 

Remaining challenges 

lack of legislation regarding open market traineeships (although there are very few); 

 
  no possibility to terminate ALMP traineeship with notice; 
  no proper recognition of ALMP-type traineeships; 
 

lack of transparency — in particular regarding allowance/compensation (ALMP-type 
traineeships). 

36 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Assessment of open market as well as ALMP-type traineeships in terms of compliance 
with QFT 

Open market traineeships 

ALMP-type 
traineeships 

Written traineeship agreement 
Written traineeship agreement concluded 
Learning and training objectives 
Objectives clarified 
Mentor/supervisor assigned 
Working conditions applicable to trainees 
Health/accident insurance and sick leave clarified 
Allowance/compensation and amount clarified 
Reasonable duration 
Duration limited to 6 months 
Conditions of longer duration clarified 
Termination allowed 
Proper recognition of traineeship 
Proper recognition through certificate 
Transparency requirements 
Allowance/compensation   
Health/accident insurance  
Hiring practices in recent years 
Employment services on financial conditions 

Fully compliant 
Partly compliant 
Not compliant 

37 

 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
 
  
 
  
 
 
 
Country fiche FRANCE 

Implementation of the Council Recommendation on a Quality Framework for 
Traineeships (2014/C 88/01) 

General description 

Open market traineeships 

In France, the legal framework formally forbids traineeships outside academic curricula, 
formal education or vocational courses. This was lastly confirmed by the Act of 10 July 2014 
specifying the traineeship framework of educational traineeships. 

In this context, traineeships are very popular in most (near in each) of the curricula offered by 
the Ministry of Education and by the Ministry of Labour from secondary school to higher 
education, also in case of lifelong learning (but only in case of accessing a diploma or 
recognised certification). 

ALMP-type traineeships 

There are 3 relevant ALMP measures delivered by the French PES, Pole Emploi: 

  The POEC / POEI (preparation opérationnelle à l’emploi — 

operational preparation for employment): 400 hours of training, 
training plan elaborated by the enterprise. The individual approach 
(POEI) can be used only in case of a sustainable job at the end of the 
training course (access only for unemployed having a sustainable 
working contract). The collective approach, the POEC (also 400 h, but 
in which one third maximum work experience)does not need a 
contractual commitment from enterprises. ). 

  The AFPR training action prior to recruiting (action de formation 
préalable au recrutement, AFPR): before integrating someone in a 
sustainable job, financial aid dedicated to training can be given to 
employers. The measure is open to unemployed who have signed a 
working contract 

  The PMSMP: work experience of one month maximum duration, 

offered to unemployed for testing a career project. 

For POEC, AFPR and PMSMP measures, the duration of the traineeship period is no more 
than one month, and in the cases of POEI and AFPR, accessing these measures can be 
possible only if the unemployed has signed a working contract before being included in the 
measure. 

Remaining challenges 

None 

38 

 
 
 
 
 
 
 
 
 
 
 
 
 
Assessment of open market as well as ALMP-type traineeships in terms of compliance 
with QFT 

Open market 
traineeships 

ALMP-type 
traineeships 

n.a. 

Written traineeship agreement 
Written traineeship agreement concluded 
Learning and training objectives 
Objectives clarified 
Mentor/supervisor assigned 
Working conditions applicable to trainees 
Health/accident insurance and sick leave clarified 
Allowance/compensation and amount clarified 
Reasonable duration 
Duration limited to 6 months 
Conditions of longer duration clarified 
Termination allowed 
Proper recognition of traineeship 
Proper recognition through certificate 
Transparency requirements 
Allowance/compensation   
Health/accident insurance  
Hiring practices in recent years 
Employment services on financial conditions 

Fully compliant 
Partly compliant 
Not compliant 

39 

 
 
 
 
 
  
  
  
  
  
 
  
 
  
  
  
 
  
 
  
  
  
 
  
 
  
 
  
  
  
 
  
  
  
 
  
 
  
 
  
 
  
 
 
 
 
 
 
 
  
 
  
 
  
 
 
 
Country fiche GERMANY 

Implementation of the Council Recommendation on a Quality Framework for 
Traineeships (2014/C 88/01) 

General description — open market and ALMP-type traineeships 

Germany  has  not  introduced  any  specific  legislation  to  implement  the  QFT,  as  previous 
legislation  already  complied  to  a  large  extent  with  the  Recommendation.  Nevertheless,  the 
Minimum  Wage  Law  coming  into  effect  on  January  2015  covers  also  traineeships  that  are 
longer  than  3  months.  The  application  of  the  Minimum  Wage  Law  ensures  an  even  higher 
level  of  compliance  with  the  QFT  (in  particular  regarding  working  conditions  and 
transparency). 
The new legislation does not cover: 

* young people below the age of 18, 
*compulsory traineeships in the context of VET and tertiary education, 
*traineeships  with  a  duration  less  than  3  months  that  provide  vocational  orientation  or 
accompany vocational training or university studies 
*long-term unemployed 
*traineeships  as  part  of  ALMP  to  prepare  for  vocational  training  and  provide  some  initial 
training  to  disadvantaged  groups  (Einstiegsqualifizierung  §  54  a  SGB  III  (Social  code)), 
Berufsausbildungsvorbereitung §§ 68 to 70 BBiG (Vocational education law)). 

However,  the  above  exemptions  from  the  Law  only  affect  the  level  of  the  remuneration  of 
internships. Other rules regarding transparency and fixing details of employment relationships 
are not affected by the exemptions. 

In addition, new guidelines on traineeships in the public sector were issued on January 2015, 
limiting the length of voluntary traineeships to 3 months in federal institutions. 

Finally,  new  guidelines  which  came  into  effect  in  August  2015  have  eased  the  access  of 
refugees and asylum seekers to traineeships (§ 32 Abs. 2 Nr. 1 Beschäftigungsverordnung). 

Remaining challenges 

 
 
 
 

lack of legislation regarding learning objectives; 
traineeships over 6 months are allowed; 
the Minimum Wage Law does not cover traineeships that are shorter than 3 months; 
the Minimum Wage Law does not require transparency on hiring practices. 

40 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Assessment of open market as well as ALMP-type traineeships in terms of compliance 
with QFT 

Open market 
traineeships 

ALMP-type traineeships 

Written traineeship agreement 
Written traineeship agreement concluded 
Learning and training objectives 
Objectives clarified 
Mentor/supervisor assigned 
Working conditions applicable to trainees 
Health/accident insurance and sick leave clarified 
Allowance/compensation and amount clarified 
Reasonable duration 
Duration limited to 6 months 
Conditions of longer duration clarified 
Termination allowed 
Proper recognition of traineeship 
Proper recognition through certificate 
Transparency requirements 
Allowance/compensation   
Health/accident insurance  
Hiring practices in recent years 
Employment services on financial conditions 

Fully compliant 
Partly compliant 
Not compliant 

41 

 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
 
  
 
  
 
 
 
Country fiche GREECE 

Implementation of the Council Recommendation on a Quality Framework for 
Traineeships (2014/C 88/01) 

General description — open market and ALMP-type traineeships 

In  Greece  there  has  been  no  new  legislation  ensuring  compliance  of  traineeships  outside 
educational curricula with the QFT, apart from a new legislation regarding work experience 
relevant to ALMPs (L. 4368/16). 

Open  market  traineeships  are  not  specifically  regulated  in  Greece,  but  are  subject  to  the 
general rules of the labour law. Thus, the trainees have to be provided with health insurance 
and they are entitled to the minimum wage. However anecdotal evidence indicates that many 
SMEs use traineeships as a form of cheap or free labour, which is illegal. 

ALMP  type  traineeships  include  very  popular  traineeship  programmes  for  graduates  of 
secondary  and  higher  education..  The  most  popular  traineeship  programme  run  by  the 
Ministry  of  Labour  and  the  PES  is  the  Voucher  programme.  It  has  been  offering  5  months 
long paid traineeships to 42 000 18-29 year old trainees since September 2014. These ALMP-
type  traineeships,  including  the  Voucher  scheme  are  compatible  to  a  large  extent  with  the 
QFT. 

Under  recent  Law  4368/2016  (Article  83),  PES  (OAED)  in  cooperation  with  enterprises  as 
well  as  with  Social  Cooperative  Enterprises  (Koin.S.Ep.),  implements  work  experience 
programmes  for  unemployed  graduates  of  secondary  and  higher  education.  All  the  relevant 
terms  and  conditions  (the  conclusion  of  a  tripartite  written  agreement  between the  PES,  the 
enterprise and the beneficiary, a daily net allowance and health and accident insurance) will 
be defined by joint ministerial decisions of the Ministers of Labour and Economy. 

Remaining challenges 

  No specific legislation covering open market traineeships. 
  Conditions for longer duration not specified; 
  No transparency regarding hiring practices in recent years. 

42 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Assessment of open market as well as ALMP-type traineeships in terms of compliance 
with QFT 

Open market 
traineeships 

ALMP-type 
traineeships 

Written traineeship agreement 
Written traineeship agreement concluded 
Learning and training objectives 
Objectives clarified 
Mentor/supervisor assigned 
Working conditions applicable to trainees 
Health/accident insurance and sick leave 
clarified 
Allowance/compensation and amount 
clarified 
Reasonable duration 
Duration limited to 6 months 
Conditions of longer duration clarified 
Termination allowed 
Proper recognition of traineeship 
Proper recognition through certificate 
Transparency requirements 
Allowance/compensation   
Health/accident insurance  
Hiring practices in recent years 
Employment services on financial conditions 

Fully compliant 
Partly compliant 
Not compliant 

No change introduced 

43 

 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
 
  
 
  
 
 
 
 
  
 
 
 
Country fiche HUNGARY 

Implementation of the Council Recommendation on a Quality Framework for 
Traineeships (2014/C 88/01) 

General description — open market and ALMP-type traineeships 

Hungary  has  not  introduced  any  new  legislation  to  implement  the  Quality  Framework  for 
Traineeships.  There  is  no  relevant  legislation  or  social  partner  agreement  in  the  pipeline  either. 
This is due to the fact that the Act on Labour Code (Act I of 2012) — or any other law in Hungary 
— does not define traineeship as a specific form of employment; and open market traineeships are 
rare in Hungary. The more frequent compulsory traineeships that are part of education curricula 
are already regulated and are more or less consistent with the principles of the QFT.51 ALMP-type 
traineeships are also regulated.52   

From a legal point of view there are three formalised and one informal way for employers to hire 
trainees as for whom it is not obligatory to complete a traineeship as part of their studies: 

1.  Through a regular employment contract subject to the Labour Code,53 
2.  Through a school cooperative, which acts as a ‘third party’ connecting the employer with 
the trainee. In this case the trainee must maintain student status. This type of employment 
relationship is also subject to the Labour Code, 

3.  Through a personal services contract (‘megbízási szerződés’) subject to the Civil Code.54 
4.  A fourth, informal way of employing trainees is to employ them without any official 

contract. 

Hungary  introduced  its  first  ESF  co-funded  ALMP-type  traineeship  programme  in  2012.  The 
programme  (SROP  2.3.4)  supported  9  month  long  paid  traineeships  for  young  qualified  career 
starters at micro, small or medium sized companies by fully or partially subsidising their wages 
and social contributions, as well as partially subsidising the wage of a mentor and the purchase of 
equipment needed for employing the trainee. 2300 trainees were involved in this programme  in 
2013-2014. A similar programme is running since August 2016 within the framework of the YG. 

Remaining challenges 

  No legislation on open market traineeships (although these are rare); 
  Duration of ALMP traineeships exceeds 6 month (although these traineeships are linked 

to work contract after the traineeship); 
  No transparency on hiring practices. 

51 Compulsory traineeships are regulated by the Government Decree 230/2012. (VIII. 28.). 
52 Act IV of 1991 on Job Assistance and Unemployment Benefits https://ec.europa.eu/migrant-integration/librarydoc/act-iv-
of-1991-on-job-assistance-and-unemployment-benefits. 
53 Act I of 2012 on the Labor Code. 
54 Act V of 2013 on the Civil Code. 

44 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Assessment of open market as well as ALMP-type traineeships in terms of compliance 
with QFT 

Open market 
traineeships 

ALMP-type 
traineeships 

Written traineeship agreement 
Written traineeship agreement concluded 
Learning and training objectives 
Objectives clarified 
Mentor/supervisor assigned 
Working conditions applicable to trainees 
Health/accident insurance and sick leave 
clarified 
Allowance/compensation and amount 
clarified 
Reasonable duration 
Duration limited to 6 months 
Conditions of longer duration clarified 
Termination allowed 
Proper recognition of traineeship 
Proper recognition through certificate 
Transparency requirements 
Allowance/compensation   
Health/accident insurance  
Hiring practices in recent years 
Employment services on financial conditions 

Fully compliant 
Partly compliant 
Not compliant 

No change 
introduced 

45 

 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
 
  
 
  
 
 
 
 
  
 
 
 
 
Country fiche IRELAND 

Implementation of the Council Recommendation on a Quality Framework for 
Traineeships (2014/C 88/01) 

General description — open market and ALMP-type traineeships 

Ireland has not introduced any new legislation in response to the Council recommendation on 
a QFT and no further legislation or social partner agreements are in the pipeline either. Open 
market traineeships are not regulated, the only relevant legislation is the National Minimum 
Wage  Act  2000:  it  sets  out  trainee  rates  of  pay  (between  75  and  90 %  of  the  national 
minimum wage, depending on the time spent in the traineeship). 

As  for  ALMP-type  traineeships,  the  most  important  programme  is  JobBridge.  This  is  a 
national  internship  scheme  operated  by  the  Department  of  Social  Protection.  Traineeships 
within  JobBridge  last  for  6  or  9  months.  Trainees,  who  must  be  registered  unemployed, 
receive an allowance of €52.50 per week on top of their existing social welfare entitlement. 
Nevertheless, in May 2016 it was announced that JobBridge would be discontinued after five 
years, with a new, more targeted scheme replacing it from September 2016. This is partly due 
to the fact that the scheme has been the subject of much debate, with some arguing that some 
employers may use the scheme to exploit unemployed young people. 

Overall, ALMP-type traineeships comply to a large extent with the QFT. 

Remaining challenges 

 

lack  of  legislation  regarding  open  market  traineeships  (apart  from  Minimum  Wage 
Act); 

  duration of certain ALMP traineeships exceed 6 months; 
  no proper recognition of ALMP traineeships; 
 

lack of transparency on hiring practices (ALMP traineeships). 

46 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Assessment of open market as well as ALMP-type traineeships in terms of compliance 
with QFT 

Open market 
traineeships 

ALMP-type 
traineeships 

Written traineeship agreement 
Written traineeship agreement concluded 
Learning and training objectives 
Objectives clarified 
Mentor/supervisor assigned 
Working conditions applicable to trainees 
Health/accident insurance and sick leave clarified 
Allowance/compensation and amount clarified 
Reasonable duration 
Duration limited to 6 months 
Conditions of longer duration clarified 
Termination allowed 
Proper recognition of traineeship 
Proper recognition through certificate 
Transparency requirements 
Allowance/compensation   
Health/accident insurance  
Hiring practices in recent years 
Employment services on financial conditions 

Fully compliant 
Partly compliant 
Not compliant 

47 

 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
 
  
 
  
 
 
 
Country fiche ITALY 

Implementation of the Council Recommendation on a Quality Framework for 
Traineeships (2014/C 88/01) 

General description — open market and ALMP-type traineeships 

While Italy has  not  updated its traineeship legislation following the adoption of the QFT in 
2014, it has since 2013 a comprehensive legislation on ALMP-type traineeships. There are no 
open market traineeships in Italy. Overall, current Italian legislation complies to a large extent 
with QFT.55 

National  guidelines  on  traineeships  were  adopted  in  the  framework  of  a  State-Region 
agreement in January 2013 (Linee guida in materia di tirocini), which were then transposed 
into  regional  legislation  by  all  regions  within  6  months.  These  guidelines  act  as  a  common 
national  regulatory  framework  setting  the  minimum  quality  standards  for  extracurricular 
traineeships,  provided  that  the  Regions  and  Autonomous  Provinces  may  improve  the 
framework defining more favourable conditions. The guidelines cover both ‘open market’ and 
ALMP-type traineeships. 

Further  to  the  quality  elements  as  promoted  by  the  QFT,  the  Italian  guidelines  also  make 
remuneration compulsory (min 300 EUR/months, however most regions decided to impose a 
higher minimum), and set the maximum of the trainee/permanent employee ratio at 10 % (for 
micro  enterprises  1  up  to  5  permanent  employees,  and  2  trainees  for  firms  with  6-20 
permanent employees). 

The Guidelines foresee that Regions are responsible of monitoring the traineeships, also using 
Compulsory Communication administrative data. 

Remaining challenges 

  Transparency of hiring chances is not part of the Italian guidelines; 
  Traineeship agreements do not need to clarify whether there is a sick leave scheme; 
  ALMP-type traineeships can have a longer duration (up to 12 months  — or even 24 

 

months for specific disadvantaged groups). 
In  general,  while  the  Italian  legislation  can  be  considered  as  a  model  among  EU 
Member  States,  the  excessive  fragmentation  of  the  system  within  a  scenario 
characterised by strong cross-regional imbalances could potentially lead to abuses. In 
the  context  of  a  fragile  economic  environment  and  high  youth  unemployment  rates 
employers may be tempted to consider traineeships simply as a way to recruit cheap 
labour. 

55 NB the Italian traineeship guidelines also served as a model for the Commission’s original 
proposal for a Council Recommendation on a Quality Framework for Traineeships. 

48 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Assessment of open market as well as ALMP-type traineeships in terms of compliance 
with QFT 

Open market 
traineeships 

ALMP-type 
traineeships 

na 

Written traineeship agreement 
Written traineeship agreement concluded 
Learning and training objectives 
Objectives clarified 
Mentor/supervisor assigned 
Working conditions applicable to trainees 
Health/accident insurance and sick leave clarified 
Allowance/compensation and amount clarified 
Reasonable duration 
Duration limited to 6 months 
Conditions of longer duration clarified 
Termination allowed 
Proper recognition of traineeship 
Proper recognition through certificate 
Transparency requirements 
Allowance/compensation   
Health/accident insurance  
Hiring practices in recent years 
Employment services on financial conditions 

Fully compliant 
Partly compliant 
Not compliant 

49 

 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
  
 
 
 
 
 
  
 
  
 
  
 
 
 
Country fiche LATVIA 

Implementation of the Council Recommendation on a Quality Framework for 
Traineeships (2014/C 88/01) 

General description — open market and ALMP-type traineeships 

Open market traineeships outside formal education are prohibited by law in Latvia (they are 
considered as undeclared work). 

ALMP-type  traineeships,  for  example  under  the  Youth  Guarantee  measure  ‘First  work 
experience’  and  ‘Subsidised  workplace’,  as  well  as  ‘First  work  experience  in  NGOs’  are 
governed  by  general  labour  law  as  there  is  a  regular  employment  contract  between  the 
unemployed  and  the  employer.  This  means  that  they  comply  with  QFT  only  in  terms  of 
working conditions and transparency regarding financial conditions, as well as partly in terms 
of learning content. 

Remaining challenges 

  No specific legislation covering open market traineeships; 
  Learning objectives not properly defined (ALMP-type traineeships); 
  Duration can exceed 6 months (certain ALMP-type traineeships); 
  No rules on proper recognition of traineeships (ALMP-type traineeships); 
  No rules on transparency regarding hiring practices (ALMP-type traineeships). 

50 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Assessment of open market as well as ALMP-type traineeships in terms of compliance 
with QFT 

Open market 
traineeships 

ALMP-type 
traineeships 

n.a. 

Written traineeship agreement 
Written traineeship agreement concluded 
Learning and training objectives 
Objectives clarified 
Mentor/supervisor assigned 
Working conditions applicable to trainees 
Health/accident insurance and sick leave clarified 
Allowance/compensation and amount clarified 
Reasonable duration 
Duration limited to 6 months 
Conditions of longer duration clarified 
Termination allowed 
Proper recognition of traineeship 
Proper recognition through certificate 
Transparency requirements 
Allowance/compensation   
Health/accident insurance  
Hiring practices in recent years 
Employment services on financial conditions 

Fully compliant 
Partly compliant 
Not compliant 

51 

 
 
 
 
 
  
  
  
  
  
 
  
 
  
  
  
 
  
 
  
  
  
 
  
 
  
 
  
  
  
 
  
  
  
 
  
 
  
 
  
 
  
 
 
 
 
 
 
 
  
 
  
 
  
 
 
 
Country fiche LITHUANIA 

Implementation of the Council Recommendation on a Quality Framework for 
Traineeships (2014/C 88/01) 

General description — open market and ALMP-type traineeships 

Lithuania passed new legislation in 2014 to allow for traineeships for young people under 29. 
There are two new measures introduced: 

1. Open market traineeships 

Voluntary practice (VP — effective as of 1 January 2015). VP is open to any young persons 
(16-29) to perform an unpaid traineeship in a company or organisation by directly concluding 
a  bilateral  agreement.  Trainees  are  covered  by  compulsory  health  insurance  and  social 
insurance against accidents at work and occupational diseases with state funds. 

2. ALMP-type traineeships 

Agreement on the acquisition of working skills (AAWS — effective as of 1 September 2014); 
AAWS  is  targeted  to  young  unemployed  (16-29),  registered  at  PES.  It  offers  a  bilateral 
agreement between the host organisation and the trainee on the acquisition of working skills. 
During the traineeship young persons shall retain the status of an unemployed person and be 
covered with compulsory health insurance by the state. There is no additional income for the 
employer or young trainee. 

Both  VP  and  AAWS  comply  with  QFT  to  a  large  extent.  The  draft  Law  on  Employment, 
currently discussed in LT Parliament, foresees to merge the two types of traineeship contracts. 
It is also foreseen to launch an additional ALMP-type traineeship that will be paid. 

Remaining challenges 

  Although all traineeships are limited to less than 6 months, conditions for longer 

durations are not clarified (both types of traineeships); 

  Transparency requirements are not respected as for hiring practices (both types of 

traineeships). 

52 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Assessment of open market as well as ALMP-type traineeships in terms of compliance 
with QFT 

Open market 
traineeships 

ALMP-type 
traineeships 

Written traineeship agreement 
Written traineeship agreement concluded 
Learning and training objectives 
Objectives clarified 
Mentor/supervisor assigned 
Working conditions applicable to trainees 
Health/accident insurance and sick leave clarified 
Allowance/compensation and amount clarified 
Reasonable duration 
Duration limited to 6 months 
Conditions of longer duration clarified 
Termination allowed 
Proper recognition of traineeship 
Proper recognition through certificate 
Transparency requirements 
Allowance/compensation   
Health/accident insurance  
Hiring practices in recent years 
Employment services on financial conditions 

Fully compliant 
Partly compliant 
Not compliant 

53 

 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
 
  
 
  
 
 
 
Country fiche LUXEMBURG 

Implementation of the Council Recommendation on a Quality Framework for 
Traineeships (2014/C 88/01) 

General description 

Open market traineeships 

The  QFT  has  not  yet  been  implemented  in  Luxemburg;  however  there  are  tripartite 
negotiations  ongoing  with  the  participation  of  social  partners  to  set  up  a  new  traineeship 
framework based on the Council Recommendation of 2014. 

In  Luxemburg  most  traineeships  are  part  of  the  educational  curricula.  In  addition,  there  are 
traineeships offered to students between 15-27 years, but outside the curricula. This type of 
traineeship  is  regulated  by  Title  V  (Articles  L.151-1  to  L.151.9)  of  the  Code  of  Work.  The 
student  signs  a  written  contract  (contrat  d’étudiant)  for  a  maximum  duration  of  2  months 
which  includes  i.a.  the  salary,  the  duration  of  the  contract,  as  well  as  the  tasks  to  be 
performed. While the student is not covered by a pension or health insurance, work accident 
insurance is guaranteed. These conditions are to a large extent in line with the QFT. 

The students also have the possibility to do a traineeship with a temporary contract (CDD) as 
a part-time employee. In this case the duration is restricted to 10 hours per week for a period 
of 4 weeks, while contracts can be signed for a period to up to 5 years. Students are covered 
by social security insurance and get a salary that does not exceed 80 % of the minimum social 
income. 

ALMP-type traineeships 

The  biggest  ALMP  programme  in  Luxemburg  that  provides  traineeships  is  ‘JobELO’.  The 
contract  offered  within  this  programme  (contrat  d’appui  emploi)  complies  to  a  large  extent 
with the QFT (except for duration which can be up to 12 months). 

Remaining challenges 

  Overall traineeship regulation is subject to successful conclusion of tripartite 

negotiations; 

  Current regulation on open market traineeships is not compliant in terms of learning 

objectives, duration and transparency; 

  Duration of ALMP-type traineeships can exceed 6 months. 

54 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Assessment of open market as well as ALMP-type traineeships in terms of compliance 
with QFT 

Open market 
traineeships 

ALMP-type 
traineeships 

Written traineeship agreement 
Written traineeship agreement concluded 
Learning and training objectives 
Objectives clarified 
Mentor/supervisor assigned 
Working conditions applicable to trainees 
Health/accident insurance and sick leave clarified 
Allowance/compensation and amount clarified 
Reasonable duration 
Duration limited to 6 months 
Conditions of longer duration clarified 
Termination allowed 
Proper recognition of traineeship 
Proper recognition through certificate 
Transparency requirements 
Allowance/compensation   
Health/accident insurance  
Hiring practices in recent years 
Employment services on financial conditions 

Fully compliant 
Partly compliant 
Not compliant 

55 

 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
 
  
 
  
 
 
 
Country fiche MALTA 

Implementation of the Council Recommendation on a Quality Framework for 
Traineeships (2014/C 88/01) 

General description — open market traineeships and ALMP-type traineeships 

Malta  has  not  passed  any  new  legislation  to  implement  the  QFT  and  there  is  no  relevant 
legislation or social partner agreement in the pipeline either. 

In Malta open market traineeships are very rare, almost non-existent. Consequently, there is 
no relevant legislation on them. As for ALMP-type traineeships, the general framework is set 
by articles 29 to 45 of the Employment and Training Services Act (Chapter 343). 

This  traineeship  framework  complies  with  the  QFT  to  a  large  extent.  One  should  however 
note that the legislation is drafted in general terms and leaves considerable discretion to the 
Minister in charge of employment, who after consultation with the Employment and Training 
Corporation, may regulate specific aspects of traineeships (e.g. the qualifications required to 
be a trainee, the period of traineeship, the remuneration rates, the number of weekly hours of 
training that shall be attended etc.) 

Remaining challenges 

  No legislation on open market traineeships (although these are very rare); 
  Some aspects of ALMP-type traineeships are only partly compliant: learning 

objectives, health insurance, transparency on hiring practices. 

56 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Assessment of open market as well as ALMP-type traineeships in terms of compliance 
with QFT 

Open market 
traineeships 

ALMP-type 
traineeships 

Written traineeship agreement 
Written traineeship agreement concluded 
Learning and training objectives 
Objectives clarified 
Mentor/supervisor assigned 
Working conditions applicable to trainees 
Health/accident insurance and sick leave clarified 
Allowance/compensation and amount clarified 
Reasonable duration 
Duration limited to 6 months 
Conditions of longer duration clarified 
Termination allowed 
Proper recognition of traineeship 
Proper recognition through certificate 
Transparency requirements 
Allowance/compensation   
Health/accident insurance  
Hiring practices in recent years 
Employment services on financial conditions 

Fully compliant 
Partly compliant 
Not compliant 

57 

 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
 
  
 
  
 
 
Country fiche THE NETHERLANDS 

Implementation of the Council Recommendation on a Quality Framework for 
Traineeships (2014/C 88/01) 

General description — open market and ALMP-type traineeships 

The Netherlands have not introduced any specific legislation to implement the QFT. There are 
no  plans  to  do  so  in  the  future  either,  as  the  Government  considers  this  falls  under  the 
responsibility of the social partners. 

While  social  partners  are  not  negotiating  towards  any  traineeship  quality  framework,  FNV 
Jong (the Youth division of the trade union FNV) has launched a website to gather more data 
on the exploitation of trainees. Trainees can anonymously file complaints, which may help to 
increase awareness of this problem. 

Existing  rules  only  partially  comply  with  the  QFT.  Since  in  the  Netherlands  trainees  are 
regarded as normal employees, working conditions including working time rules are generally 
respected.  There is  also a  general  health/accident insurance coverage to  all trainees. Further 
than  that,  only  recommendations  exist  regarding  the  conclusion  of  a  traineeship  agreement, 
learning  content  and  transparency  requirements.  However  there  is  no  particular  rule  or 
recommendation for the duration and the recognition of traineeships, neither for transparency 
of hiring practices. 

Recommendations  are  promoted  through  websites  and  other  channels  of  government-
supported civil society organisations and social partners. 

Remaining challenges 

  Lack of enforceable legislation regarding 

o  duration, 
o  recognition 
o 

transparency. 

58 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Assessment of open market as well as ALMP-type traineeships in terms of compliance 
with QFT 

Open market 
traineeships 

ALMP-type 
traineeships 

Written traineeship agreement 
Written traineeship agreement concluded 
Learning and training objectives 
Objectives clarified 
Mentor/supervisor assigned 
Working conditions applicable to trainees 
Health/accident insurance and sick leave clarified 
Allowance/compensation and amount clarified 
Reasonable duration 
Duration limited to 6 months 
Conditions of longer duration clarified 
Termination allowed 
Proper recognition of traineeship 
Proper recognition through certificate 
Transparency requirements 
Allowance/compensation   
Health/accident insurance  
Hiring practices in recent years 
Employment services on financial conditions 

Fully compliant 
Partly compliant 
Not compliant 

59 

 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
 
  
 
  
 
 
 
Country fiche POLAND 

Implementation of the Council Recommendation on a Quality Framework for 
Traineeships (2014/C 88/01) 

General description 

The  Act  of  17  July  2009  on  postgraduate  internships  (Journal  of  Laws  No  127,  item  1052) 
shows partial compliance with the QFT. Although a proposal was submitted in August 2015 
to the Sejm (Parliament) by deputies of the (then) governing PO to amend the above Act so 
that it fully complies with the QFT, this legal proposal was put on hold after the elections in 
October 2015. 

Open market traineeships 

Current  legislation  on  open  market  traineeships  foresees  a  written  agreement  that  should 
include the tasks of the trainee, the duration, weekly working time, financial benefits (if any). 
The  legislation  does  not  require  the  definition  of  learning  objectives,  and  there  is  no 
obligation  to  appoint  a  mentor/supervisor.  While  in  terms  of  working  conditions  the  QFT 
requirements  are  mostly  respected,  health  insurance  and  remuneration  are  not  compulsory; 
consequently,  a  large  proportion  of  the  traineeships  are  performed  unpaid.  Transparency  on 
financial  conditions  is  respected,  but  not  on  hiring  chances.  The  duration  of  open  market 
traineeships is limited to 3 months, but conditions for an extension are not defined. 

ALMP-type traineeships 

A  written  agreement  is  also  required  for  ALMP-type  traineeships.  The  agreement  shall 
include the programme of the traineeship, but provisions on the learning content apply only to 
certain  ALMP-type  traineeships  (those  within  the  POWER  programme,  funded  by  ESF). 
ALMP-type traineeships also foresee a mentor/supervisor. QFT recommendations on working 
conditions  and  transparency  are  largely  respected,  except  transparency  on  hiring  chances. 
Duration of ALMP-type traineeships can be between 3 and 6 months. 

Remaining challenges 

  No  requirement  to  define  learning  content  and to  appoint  a  mentor/supervisor  in  the 

case of open market traineeships; 

  Conditions for an extension are not defined; 
  Lack of transparency on hiring chances. 

Although  the  proposal  for  amendment  of  the  2009  Act  on  postgraduate  traineeships  was 
offering a solution to these problems, it is unlikely that the proposed amendment will pass in 
the current term, taking into consideration a significant change in the distribution of forces in 
parliament and change in government policy. 

60 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Assessment of open market as well as ALMP-type traineeships in terms of compliance 
with QFT 

Open market 
traineeships 

ALMP-type 
traineeships 

Written traineeship agreement 
Written traineeship agreement concluded 
Learning and training objectives 
Objectives clarified 
Mentor/supervisor assigned 
Working conditions applicable to trainees 
Health/accident insurance and sick leave clarified 
Allowance/compensation and amount clarified 
Reasonable duration 
Duration limited to 6 months 
Conditions of longer duration clarified 
Termination allowed 
Proper recognition of traineeship 
Proper recognition through certificate 
Transparency requirements 
Allowance/compensation   
Health/accident insurance  
Hiring practices in recent years 
Employment services on financial conditions 

Fully compliant 
Partly compliant 
Not compliant 

61 

 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
 
  
 
  
 
 
 
Country fiche PORTUGAL 

Implementation of the Council Recommendation on a Quality Framework for 
Traineeships (2014/C 88/01) 

General description — open market and ALMP traineeships 

Portugal  updated  its  legislation  on  ALMP-type  traineeships  in  2014  with  a  view  to  better 
comply  with  QFT.  Portaria56  149-B/2014  refers  in  particular  to  the  ALMP  programme 
‘Employment  Traineeships’  (Estágios  Emprego)  which  involves  on  average  70 000  young 
trainees (18-30 year old) per year. Traineeships under this programme comply with QFT to a 
large extent, although they can be longer than 6 months (with a maximum of 9 months). 

The stipulations regarding traineeships under other (smaller) ALMP measures ‘Young Active 
Employment’ and ‘Reactivate’ (created by the Portaria 15/2014 and the Portaria 86/2015) are 
very  similar  to  those  regarding  the  ‘Employment  Traineeships’  and  also  comply  to  a  large 
extent with QFT (also in terms of duration as these are limited to 6 months). 

Open market traineeships are regulated by Decree-Law 66/2011. This regulation has not been 
reviewed since 2011. This Decree-Law was a result of a broader tripartite agreement on the 
reregulation of labour relations that had been signed in 2008. This agreement stipulated that 
unpaid traineeships should be forbidden. 

In general Portuguese legislation on traineeships meets to a large extent the requirements of 
the Council Recommendation on a QFT. 

Remaining challenges 

  No obligation to specify learning objectives for open market traineeships (although 

there should be a mentor); 

  Duration of traineeships can be longer than 6 months (both open market and certain 

ALMP); 

  Transparency requirements on hiring practices are not respected (open market 

traineeships). 

56  

A ‘Portaria’ is a ministerial order. 

62 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Assessment of open market as well as ALMP-type traineeships in terms of compliance 
with QFT 

Open market 
traineeships 

ALMP-type 
traineeships 

Written traineeship agreement 
Written traineeship agreement concluded 
Learning and training objectives 
Objectives clarified 
Mentor/supervisor assigned 
Working conditions applicable to trainees 
Health/accident insurance and sick leave clarified 
Allowance/compensation and amount clarified 
Reasonable duration 
Duration limited to 6 months 
Conditions of longer duration clarified 
Termination allowed 
Proper recognition of traineeship 
Proper recognition through certificate 
Transparency requirements 
Allowance/compensation   
Health/accident insurance  
Hiring practices in recent years 
Employment services on financial conditions 

Fully compliant 
Partly compliant 
Not compliant 

63 

 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
 
  
 
  
 
 
 
Country fiche ROMANIA 

Implementation of the Council Recommendation on a Quality Framework for 
Traineeships (2014/C 88/01) 

General description — open market and ALMP-type traineeships 

While Romania has not updated its traineeship legislation following the adoption of the QFT 
in 2014 and there are no initiatives in the pipeline either, since 2013 there is a comprehensive 
legislation  on  traineeships  falling  under  the  scope  of  the  QFT  (Law  no.335/2013).  Overall, 
current Romanian legislation complies to a large extent with QFT. 

The legislative framework covers both open market and ALMP-type traineeships, while not 
covering traineeships that are either part of the academic curricula or are regulated in by other 
pieces of special regulation. 

As  for  learning  content,  while  the  law  provides  for  mentoring  in  the  case  of  both  types  of 
traineeships,  it  is  not  sufficiently  detailed  on  the  definition  of  learning  objectives.  Working 
conditions of trainees are the same as for employees. The Law also ensures transparency, with 
the exception of hiring practices in recent years. The duration of the traineeships is fixed at 6 
months. 

Remaining challenges 

Learning objectives should be better defined (open market traineeships); 
Lack of transparency on hiring practices (both types of traineeships). 

64 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Assessment of open market as well as ALMP-type traineeships in terms of compliance 
with QFT 

Open market 
traineeships 

ALMP-type 
traineeships 

Written traineeship agreement 
Written traineeship agreement concluded 
Learning and training objectives 
Objectives clarified 
Mentor/supervisor assigned 
Working conditions applicable to trainees 
Health/accident insurance and sick leave 
clarified 
Allowance/compensation and amount 
clarified 
Reasonable duration 
Duration limited to 6 months 
Conditions of longer duration clarified 
Termination allowed 
Proper recognition of traineeship 
Proper recognition through certificate 
Transparency requirements 
Allowance/compensation   
Health/accident insurance  
Hiring practices in recent years 
Employment services on financial conditions 

Fully compliant 
Partly compliant 
Not compliant 

65 

 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
 
  
 
  
 
 
 
 
Country fiche SLOVAKIA 

Implementation of the Council Recommendation on a Quality Framework for 
Traineeships (2014/C 88/01) 

General description 

Slovakia has not introduced any new legislation to implement the QFT. There is no relevant 
legislation or social partner agreement in the pipeline either. 

Open market traineeships 

No  regulatory  framework  exists  for  traineeships  in  the  open  market.  This  is  due  to  the  fact 
that open market traineeships are rare in Slovakia. Young people prefer to engage in student 
jobs: according to the 2013 Eurobarometer on traineeships, 52 % of Slovak respondents had a 
student  job  experience  against  8 %  involved  in  a  traineeship.  For  the  latter  the  EU  average 
was 46 %. 

ALMP-type traineeships 

Traineeships  provided  within  ALMP  schemes  are  regulated  by  the  Act  on  employment 
services  (No  5/2004  Coll.)  The  major  ALMP  programme  to  offer  traineeships  is  called 
‘Graduate  practice’.  It  is  offered  to  young  people  under  26  who  have  completed  a  relevant 
level of education in full-time study less than two years ago and have not had a regular paid 
job  since  then.  Graduate  practice  takes  place  in  a  workplace  during  3  to  6  months  at 
maximum  20  hours  per  week.  The  labour  office  provides  the  trainee  with  a  monthly 
allowance ( 65 % of the minimum subsistence level = EUR 128). 

Another ALMP programme, ‘Through work experience to employment’ combines mentored 
employment  with  wage  subsidies  for  hiring  young  job  seekers.  Financial  allowances  are 
granted  for  a  maximum  of  9  months  to  the  employer  who  recruits  a  young  job  seeker  on  a 
newly created job: 
- contribution to mentoring (the mentor is chosen by the employer from its own employees) 
- contribution to cover part of the total labour costs of the young person 
-  contribution  to  cover  part  of  the  necessary  costs  related  to  the  mentoring  and  gaining  of 
work experience. 

Overall, ALMP-type traineeships comply to a large extent with QFT. 

Remaining challenges 

  Lack of regulation on open market traineeships; 
  Lack of transparency regarding hiring practices (ALMP-type traineeships). 

66 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Assessment of open market as well as ALMP-type traineeships in terms of compliance 
with QFT 

Open market 
traineeships 

ALMP-type 
traineeships 

Written traineeship agreement 
Written traineeship agreement concluded 
Learning and training objectives 
Objectives clarified 
Mentor/supervisor assigned 
Working conditions applicable to trainees 
Health/accident insurance and sick leave clarified 
Allowance/compensation and amount clarified 
Reasonable duration 
Duration limited to 6 months 
Conditions of longer duration clarified 
Termination allowed 
Proper recognition of traineeship 
Proper recognition through certificate 
Transparency requirements 
Allowance/compensation   
Health/accident insurance  
Hiring practices in recent years 
Employment services on financial conditions 

Fully compliant 
Partly compliant 
Not compliant 

67 

 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
 
  
 
  
 
 
 
Country fiche SLOVENIA 

Implementation of the Council Recommendation on a Quality Framework for 
Traineeships (2014/C 88/01) 

General description — Open market traineeships and ALMP-type traineeships 

Slovenia has not introduced any new legislation since 2014 to implement the QFT. There is 
no  relevant  legislation  or  social  partner  agreement  in  the  pipeline  either,  except  the 
recommendations  given  to  ministries  by  the  Government  of  Slovenia  to  abolish  voluntary 
(unpaid)  traineeships  and  accordingly  change  the  legislations.  On  the  basis  of  these 
recommendations relevant sectoral legislation is being changed and/or voluntary traineeship is 
no longer used in practice. 

The  Employment  Relationship  Act  (2013)  provides  a  general  framework  for  traineeships  in 
Slovenia. Its provisions apply to both open market and ALMP measures. On the basis of these 
general  guidelines  each  sector  defines  more  precise  provisions  for  traineeships  within  the 
branch’s Acts or collective agreements. These are in general compliant with the QFT. 

Remaining challenges 

  Duration of traineeships can exceed 6 months (up to one year, extendable under 

certain circumstances); 

  Lack of transparency of hiring practices. 

68 

 
 
 
 
 
 
 
 
 
 
 
 
 
Assessment of open market as well as ALMP-type traineeships in terms of compliance 
with QFT 

Open market traineeships 

ALMP-type 
traineeships 

Written traineeship agreement 
Written traineeship agreement concluded 
Learning and training objectives 
Objectives clarified 
Mentor/supervisor assigned 
Working conditions applicable to trainees 
Health/accident insurance and sick leave clarified 
Allowance/compensation and amount clarified 
Reasonable duration 
Duration limited to 6 months 
Conditions of longer duration clarified 
Termination allowed 
Proper recognition of traineeship 
Proper recognition through certificate 
Transparency requirements 
Allowance/compensation   
Health/accident insurance  
Hiring practices in recent years 
Employment services on financial conditions 

Fully compliant 
Partly compliant 
Not compliant 

69 

 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
 
  
 
  
 
 
 
Country fiche SPAIN 

Implementation of the Council Recommendation on a Quality Framework for 
Traineeships (2014/C 88/01) 

General description — open market and ALMP-type traineeships 

While  Spain  has  not  updated  its  traineeship  legislation  following  the  adoption  of  the  QFT57  in 
2014, it has recent legislation on traineeships falling under the scope of the QFT. Overall, current 
Spanish legislation complies to a large extent with QFT. 

1) Prácticas laborales 
Art  13  of  the  Law  11/2013  regulates  the  traineeship  work  contract  (Contrato  de  trabajo  en 
prácticas).  Such  labour  traineeship  contracts  (prácticas  laborales)  can  be  offered  to  graduates 
under  30  with  a  diploma  (university,  vocational  education  and  training).  For  this  two  year 
traineeship remuneration must be proportional to an equivalent post, reaching at least 60 % of the 
average  salary  during  the  first  year  and  75 %  during  the  second  year.  It  cannot  be  below  the 
minimum wage (655.20 per month, 14 payments per year). Trainees also benefit from full Social 
Security coverage. The norm also sets up hiring incentives for companies or self-employed when 
hiring  young  workers  under  30  years  old  with  a  traineeship  contract.  The  incentives  consist  of 
50 % of Social Security rebates, up to 75 % if the worker was already performing a non-labour 
traineeship in the same company. 

2) Prácticas no laborales 
Royal  Decrees  1543/2011  and  1493/2011introduced  non-labour  traineeships  (prácticas  no 
laborales).  These  do  not  involve  a  labour  relationship  between  the  trainee  and  the  host 
organisation,  and  are  limited  to  graduates  aged  18-25  without  any  working  experience.  The 
duration must be between 3 and 9 months. These traineeships must offer a remuneration of at least 
of 80 % of IPREM (Public Income Indicator of Multiple Effects, 532.51 euro per month in 2016, 
80 % equals to 426 euro) and include Social Security coverage. These traineeships can be offered 
through the PES, through the open market, in the website of companies or in job portals, through 
specific programmes by foundations or even through the employment offices of universities. 

Social  partners  are  also  committed  to  design  and  implement  youth  policies  and  to  promote 
synergies  with  their  own  initiatives.  The  new  Agreement  for  Employment  and  Collective 
Bargaining  for  2015-2017  (ANC  2015-2017),  signed  the  8th  of  June  of  2015  by  the  main 
representative trade unions (CCOO and UGT) and employers’ organisations (CEOE, CEPYME), 
states  that  social  partners  will  prioritise  labour  traineeships  rather  than  non-labour  ones.  The 
Agreement  also  highlights  the  importance  of  curricular  traineeships,  such  as  Dual  Vocational 
Training, and that traineeships serve as an entry to stable employment, becoming regular jobs in 
the companies that provide them. 
This strategy, although approved in 2013, briefly shows the pipeline of expected measures to be 
taken  by  the  government  related  to  youth  employment  in  the  2013-2016  period.  However,  this 
strategy finishes this year. 

Remaining challenges 

  No mentor assigned in the case of prácticas laborales; 
  Duration of traineeships can be longer than 6 months; 

57 NB there has been new legislation for traineeships outside the scope of the QFT (see Royal Decree 592/2014). 

70 

 
 
 
 
 
 
 
 
 
 
                                                 
 

Insufficient transparency regarding allowance and hiring practices in recent years. 
Assessment of open market as well as ALMP-type traineeships in terms of compliance 
with QFT 

Open market 
traineeships 

ALMP-type 
traineeships 

Written traineeship agreement 
Written traineeship agreement concluded 
Learning and training objectives 
Objectives clarified 
Mentor/supervisor assigned 
Working conditions applicable to trainees 
Health/accident insurance and sick leave clarified 
Allowance/compensation and amount clarified 
Reasonable duration 
Duration limited to 6 months 
Conditions of longer duration clarified 
Termination allowed 
Proper recognition of traineeship 
Proper recognition through certificate 
Transparency requirements 
Allowance/compensation   
Health/accident insurance  
Hiring practices in recent years 
Employment services on financial conditions 

Fully compliant 
Partly compliant 
Not compliant 

71 

 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
 
  
 
  
 
 
 
Country fiche SWEDEN 

Implementation of the Council Recommendation on a Quality Framework for 
Traineeships (2014/C 88/01) 

General description– open market and ALMP-type traineeships 

Sweden  has  not  introduced  any  new  legislation  in  response  to  the  Council  recommendation 
and no further legislation or social partner agreements are in the pipeline. 

While  there  is  no  specific  legislation  regarding  open  market  traineeships,  trainees  are  in 
general  considered  as  employees  and  are  protected  in  accordance  with  Swedish  labour  law, 
health and safety at work legislation and collective agreements applicable at the workplace. 
As  for  ALMP-type  traineeships,  it  is  the  Regulation  on  Labour  Market  Programmes 
(Förordning  om  arbetsmarknadspolitiska  program,  SFS  2000:634)  that  provides  a  legal 
framework.  Other  relevant  legislation  in  the  area  is  the  Regulation  on  the  Labour  Market 
Policy  Operations  (Förordning  om  den  arbetsmarknadspolitiska  verksamheten,  SFS 
2000:628),  Regulation  on  Activity  Support  (Förordning  om  aktivitetsstöd,  SFS  1996:1100) 
and  Act  on  Labour  Market  Programmes  (Lag  om  arbetsmarknadspolitiska  program,  SFS 
2000:625). 

The programme ‘Vocational Introduction Employment’ was launched in 2014. It is targeted at 
young job seekers (15-24 years) registered at PES and unemployed for at least 3 months over 
a  4  month  period.  The  trainee  receives  a  wage  of  at  least  75  per  cent  of  the  current 
collectively agreed wage and is covered by social insurance. The duration is at least 6 months. 
The employer must be able to offer the young person supervision and training in at least 15 % 
of the time. The employer receives for up to 12 months a compensation corresponding to the 
payroll  tax  (31.42  per  cent  of  the  labour  cost)  as  well  as  a  compensation  for  supervision 
amounting  to  SEK  115  (around  €13  per  day).  Since  June  2016  the  Vocational  Introduction 
Employment is also open for people over 25 years of age who have been unemployed for 12 
months, as well as some for the new arrivals registered at PES. 

A  new  traineeships  programme  since  November  2015  is  targeted  at  young  people  (20-25 
years old) registered at PES and unemployed for at least six months (three months since June 
2016). These traineeships can take place either in the welfare sector (health care, elderly care, 
etc.) or in occupations with shortage of employees. The participant receives a wage and other 
employment benefits according to the sector’s collective agreement. The duration is 3 to 12 
months.  The  employer  receives  a  wage  subsidy  covering  85  per  cent  of  labour  costs  in  the 
welfare  sector  plus  a  grant  of  SEK  100  per  day  for  supervision/mentorships.  The 
compensation  is  50 %  of  wage  cost  for  trainee  jobs  in  the  second  case  (occupations  with 
shortage of employees). Since June 2016 the traineeships programme is open for people over 
25 who have been unemployed for 12 months, as well as for new arrivals registered at PES 
who are 20 years or older. Overall, ALMP-type traineeships comply to a large extent with the 
QFT. 

Remaining challenges 

 
lack of legislation regarding open market traineeships; 
  duration of ALMP-type traineeships can exceed 6 months; 
 

lack of transparency on hiring practices (ALMP-type traineeships). 

72 

 
 
 
 
 
 
 
 
 
 
Assessment of open market as well as ALMP-type traineeships in terms of compliance 
with QFT 

Open market 
traineeships 

ALMP-type 
traineeships 

Written traineeship agreement 
Written traineeship agreement concluded 
Learning and training objectives 
Objectives clarified 
Mentor/supervisor assigned 
Working conditions applicable to trainees 
Health/accident insurance and sick leave clarified 
Allowance/compensation and amount clarified 
Reasonable duration 
Duration limited to 6 months 
Conditions of longer duration clarified 
Termination allowed 
Proper recognition of traineeship 
Proper recognition through certificate 
Transparency requirements 
Allowance/compensation   
Health/accident insurance  
Hiring practices in recent years 
Employment services on financial conditions 

Fully compliant 
Partly compliant 
Not compliant 

73 

 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
  
 
  
 
  
 
 
 
Country fiche UNITED KINGDOM 

Implementation of the Council Recommendation on a Quality Framework for 
Traineeships (2014/C 88/01) 

General description 

Open market traineeships (internships) 

The UK opted not to implement the QFT. Nevertheless, the UK remains committed to raising 
the quality of ‘internships’, in particular through a voluntary approach that involves codes of 
good  practice.  The  most  prominent  of  such  voluntary  codes  is  the  Common  Best  Practice 
Code  for  High  Quality  Internships.58  It  was  published  in  2015  by  the  Department  for 
Business, Innovation and Skills (BIS), but is the product of the Gateways to the Professions 
Collaboration Forum.59 The code of good practice addresses most of the areas covered by the 
QFT  but  does  not  comply  in  terms  of  the  duration  of  internship,  as  well  as  transparency 
regarding hiring practices. 

ALMP-type traineeships 

‘Traineeships’  were  introduced  from  August  2013  and  aim  to  support  16-24  year  old 
unemployed in preparing them for a job or apprenticeship. The young person is referred to a 
Traineeship by jobcentres but is not obliged to accept it. The maximum time for participation 
on  a  Traineeship  is  six  months  with  a  minimum  requirement  of  six  weeks.  Those  on  a 
traineeship are not required to be paid (they fall under an exemption in the National Minimum 
Wage) though employers can voluntarily do so. 

The  ALMP-type  traineeships  broadly  comply  with  the  provisions  in  the  QFT  with  the 
exception of the recognition through certification — in the UK it is not a requirement. 

Remaining challenges 

  There code contains limited guidance on learning content; 
  The  code  recommends  internships  to  be  between  6  weeks  and  12  months,  with  a 

typical length of 3 months; 

  There is no recommendation proper recognition; 
  There is a lack of transparency regarding hiring practices, while many traineeships are 

unpaid. 

58 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/251483/bis-13-1085-best-practice-code-
high-quality-internships.pdf . 
59 The Gateways to the Professions Collaborative Forum is an ad hoc advisory body. Its membership is 
voluntary and represents around 60 professional bodies and related organisations. It was re-launched in January 
2010 in response to recommendations of the Panel on Fair Access to the Professions. 

74 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Assessment of open market as well as ALMP-type traineeships in terms of compliance 
with QFT 

Open market 
traineeships 

ALMP-type 
traineeships 

Written traineeship agreement 
Written traineeship agreement concluded 
Learning and training objectives 
Objectives clarified 
Mentor/supervisor assigned 
Working conditions applicable to trainees 
Health/accident insurance and sick leave clarified 
Allowance/compensation and amount clarified 
Reasonable duration 
Duration limited to 6 months 
Conditions of longer duration clarified 
Termination allowed 
Proper recognition of traineeship 
Proper recognition through certificate 
Transparency requirements 
Allowance/compensation   
Health/accident insurance  
Hiring practices in recent years 
Employment services on financial conditions 

Fully compliant 
Partly compliant 
Not compliant 

75