Proposal for a COUNCIL RECOMMENDATION on a reinforced Quality Framework for Traineeships
Date: 2024-03-20
Institutions: Directorate-General for Employment, Social Affairs and Inclusion, European Commission
Subjects: EU employment policy, integration into employment, labour market, school-working life relations, traineeship, working conditions, young person, young worker, youth employment

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   EUROPEAN COMMISSION  Brussels, 20.3.2024  COM(2024) 133 final 2024/0069 (NLE)  Proposal for a COUNCIL RECOMMENDATION on a reinforced Quality Framework for Traineeships {SEC(2024) 97 final} - {SWD(2024) 66 final} - {SWD(2024) 67 final} - {SWD(2024) 68 final}  
 
EXPLANATORY MEMORANDUM 

1. 

CONTEXT OF THE PROPOSAL 

Reasons for and objectives of the proposal 

• 
In  her  Political  Guidelines  (1),  President  von  der  Leyen  stressed  the  need  to  strengthen 
Europe’s social market economy and to foster “growth which creates quality jobs, especially 
for young people”.  

Youth unemployment remains a persistent challenge in the EU, with the youth unemployment 
rate  being  more  than  twice  as  high  as  the  overall  unemployment  rate  (2).  A  particular 
challenge  lies  in  activating  more  young  people  who  are  not  in  employment,  education  or 
training (NEETs) and who face specific obstacles that hinder their participation in the labour 
market. Therefore, the European Pillar of Social Rights Action Plan (3) sets out the target of 
decreasing the rate of young people aged 15-29 who are NEETs from 12.6% (2019) to 9% by 
2030 by improving their employment prospects. 

Traineeships can provide an opportunity for young people to gain practical and professional 
experience, improve their skills and thereby facilitate their access to the labour market. They 
offer an opportunity for employers to attract, train and retain their staff. However, the value of 
a  traineeship  depends  on  its  quality.  A  quality  traineeship  requires  fair  and  transparent 
working conditions and adequate learning content. Moreover, inclusive traineeships can help 
provide  opportunities  for  everyone  to  access  the  labour  market,  including  young  people  in 
vulnerable situations. 

According to estimations based on the European Labour Force Survey (EU-LFS) data, there 
are 3.1 million trainees in the EU (2019 data) out of which 1.6 million are paid trainees and 
1.5 million are unpaid. An increasing number of trainees in the EU participate in cross-border 
traineeships  (21%  of  trainees  in  2023  compared  to  9%  in  2013)  (4),  demonstrating  the 
potential of traineeships to contribute to fair labour mobility in the EU. Estimates also indicate 
that in 2019 around 370 000 paid trainees (5) did a traineeship of a long duration (more than 6 
months), including consecutive/repeated ones with the same employer. Out of these, around 
100 000 trainees did a traineeship of a long duration with poor learning content (6). 

The  2014  Council  Recommendation  on  a  Quality  Framework  for  Traineeships  (QFT)  is  an 
important  reference  point  for  determining  what  constitutes  a  quality  traineeship.  It  sets  out 
guidelines for traineeships outside education curricula and mandatory professional training. 

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5 
6 

Political  Guidelines  for  the  Next  European  Commission  2019-2024.  ‘A  Union  that  Strives  for  More.        
My Agenda for Europe.’ Available online. 
Youth unemployment (15-25 years) was 14.9% in January 2024, compared to a general unemployment 
rate (20-64 years) of 6.0% (Eurostat). 
COM(2021) 102 final. 
Flash Eurobarometer 523 (2964 / FL523). 
This does not include traineeships which are mandatory to access a profession. 
These numbers should be interpreted with caution as they are based on the combination of the results of 
Flash  Eurobarometer  523  (share  of  trainees  who  did  traineeships  with  a  total  duration  longer  than  6 
months  who  also  stated  that  they  did  not  learn  professionally  useful  things)  and  EU-LFS  data  on  the 
number of paid trainees.  

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In its 2023 evaluation of this Council Recommendation (7), the Commission found indications 
that the QFT had a positive impact on the quality of traineeships in the EU. It also confirmed 
that  traineeships  continue  to  be  an  important  pathway  for  young  people  to  enter  the  labour 
market.  In  addition,  quality  traineeships  can  be  useful  upskilling  and/or  reskilling 
opportunities for people of any age to acquire practical skills on the job to set their career in a 
new direction. 

However,  the  evaluation  also  highlighted  areas  that  could  be  further  strengthened  and 
improved.  For  instance,  it  recommended  better  integrating  quality  principles  in  national 
legislation,  in  particular  for  open-market  traineeships  (OMTs),  stronger  monitoring  and 
enforcement to ensure the application of the quality principles on the ground and increasing 
awareness amongst various key stakeholders. The need for stronger support to employers, for 
example, through financial support and practical guidance, was also highlighted. Furthermore, 
the  evaluation  stressed  that  efforts  to  provide  more  concrete  and  practical  information  to 
young people on cross-border traineeships should be stepped up. It also identified additional 
quality  criteria,  such  as  fair  pay  and  social  protection,  rules  on  remote/hybrid  traineeships, 
better  addressing  the  needs  of  groups  in  vulnerable  situations,  and  strengthened  support  to 
trainees  during  and  after  the  traineeship.  Moreover,  the  evaluation  noted  the  possibility  of 
extending the scope of QFT from OMTs and traineeships that are part of active labour market 
policies  (ALMP)  to  also  cover  other  traineeships,  such  as  those  that  are  part  of  formal 
education and training curricula. 

Various stakeholders called on the Commission to improve the quality of traineeships: 

•  The report on the final outcome of the Conference on the Future of Europe (8) includes 
the  call  to  ensure  that  young  people’s  traineeships  and  jobs  comply  with  quality 
standards,  including  on  pay,  and  that  unpaid  internships  on  the  labour  market  and 
outside formal education are banned through a legal instrument. 

• 

• 

In  its  Opinion  “The  Equal  Treatment  of  Young  People  in  the  Labour  Market”  of  15 
June  2023  (9),  the  European  Economic  and  Social  Committee  (EESC)  noted  that 
traineeships  should  offer  good  quality  learning  content  and  adequate  working 
conditions, and should not be a substitute for regular jobs or a precondition for a job 
placement. 
In its Opinion “Youth Employment Support: a Bridge to Jobs for the Next Generation 
Reinforcing  the  Youth  Guarantee”  of  5  February  2021  (10),  the  Committee  of  the 
Regions  considered  that  traineeships  and  apprenticeships  should  primarily  provide  a 
learning experience for young people, which can help them to decide on their future 
career and to develop their skills in order to access permanent employment. 

In particular, the European Parliament adopted on 14 June 2023 a resolution based on Article 
225  TFEU  (11) calling  on  the  Commission  to  update  and  strengthen  the  2014  Council 
Recommendation  and  to  turn  it  into  a  stronger  legislative  instrument.  It  also  called  on  the 
Commission to ensure minimum quality standards for traineeships, including pay. 

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8 
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10 
11 

Available online.  
Conference on the Future of Europe. Report on the final outcome. May 2022. 
Available online.  
Available online. 
Available online. 

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In  this  context,  the  Commission  announced  an  update  of  the  Quality  Framework  for 
Traineeships in its 2023 Commission Work Programme (12), to address issues including fair 
pay  and  access  to  social  protection,  as  part  of  its  engagement  to  implement  the  European 
Pillar  of  Social  Rights  Action  Plan  and  to  reach  the  EU’s  2030  targets  in  the  areas  of 
employment, skills, and poverty reduction. 

The  proposed  recommendation  aims  to  improve  the  quality  of  traineeships,  in  particular  as 
regards  learning  and  training  content  and  working  conditions,  with  the  aim  of  easing  the 
transition  from  education,  unemployment  or  inactivity  to  work.  It  applies  to  all  trainees, 
regardless of their employment status. It applies to trainees who are workers only insofar and 
to the extent that equivalent or more favourable provisions are not laid down in EU law. 

As  for  types  of  traineeships,  the  proposed  recommendation  extends  the  scope  of  the  2014 
Recommendation (covering open-market traineeships and traineeships that are part of active 
labour market policies) to cover also traineeships that are part of curricula of formal education 
and training and those of which their completion is mandatory to access a specific profession 
(e.g., medicine, architecture, etc.). 

is  based  on 

the  findings  of 

This  proposal 
the  2014  Council 
Recommendation,  the  European  Parliament’s  resolution,  the  views  gathered  through  the 
consultation  of  social  partners  at  EU  level  in  line  with  Article  154  of  the  Treaty  on  the 
Functioning of the European Union (TFEU), the views raised by other stakeholders, evidence 
collected  through  the  study  supporting  the  initiative  on  quality  traineeships  (13)  and  the 
Eurobarometer survey mentioned above. 

the  evaluation  of 

Alongside the proposed updated recommendation, the Commission also proposes a directive 
(COM(2024)  132)  focused  on  supporting  Member  States  in  improving  and  enforcing  the 
working  conditions  of  trainees  who  are  workers  and  in  combating  regular  employment 
relationships  disguised  as  traineeships.  The  proposed  directive  applies  to  trainees  in  the  EU 
who have an employment contract or employment relationship as set out in the law, collective 
agreements or practices in force in the Member States, and that are in line with consideration 
to the case-law of the Court of Justice of the European Union. 

• 

Consistency with existing policy provisions in the policy area 

As  part  of  the  European  Year  of  Skills,  the  EU  has  set  out  to  promote  a  mindset  where 
upskilling  and reskilling are the norm. Closing skills  gaps and addressing skills mismatches 
across  the  EU  will  boost  competitiveness,  in  particular  of  micro,  small  and  medium-sized 
enterprises  by  better  matching  employers’  needs  with  peoples’  skills  and  aspirations.  Equal 
access to skills development and work-based learning will help reduce inequalities, notably by 
empowering  people  to  fully  participate  in  the  economy  and  society.  The  European  Year  of 
Skills  follows  the  European  Year  of  Youth,  which  emphasised  the  need  to  provide  further 
impetus to the creation of quality employment opportunities for young people in line with the 
eleven  youth  goals  of  the  2019-2027  EU  Youth  Strategy  (14).  In  its  Communication  on  the 
European Year of Youth 2022, the Commission committed to updating its quality framework 

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COM(2022) 548 final. 
‘Study exploring the context, challenges and possible solution in relation to  the quality of traineeships             
in  the  EU’  by  a  consortium  of  Ernst  &  Young (EY),  Centre  of  European  Policy  Studies  (CEPS)  and 
Open Evidence (forthcoming). 
OJ C 456, 18.12.2018, p. 16. 

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for  traineeships  in  2024  to  address  issues  including  fair  pay  and  access  to  social  protection 
(15). 

The  Commission’s  Youth  Employment  Support  package  (16)  of  July  2020  proposed 
Recommendations  on  a  Bridge  to  jobs  -  reinforcing  the  Youth  Guarantee  (17)  and  a 
modernised  European  framework  for  vocational  education  and  training,  both  of  which  the 
Council adopted (18). The former specifically recommends that traineeship offers comply with 
the minimum standards laid out in the QFT. The latter sets out key principles for ensuring that 
vocational education and training adapts swiftly to labour market needs and provides quality 
learning  opportunities  for  young  people  and  adults.  It  places  a  strong  emphasis  on  better 
opportunities for work-based learning and improved quality assurance. 

In  a  similar  way  to  traineeships,  apprenticeships  are  an  important  pathway  to  facilitate 
transitions  to  the  labour  market.  The  Youth  Employment  Support  package  gave  a  renewed 
impetus to apprenticeships, including through the European Alliance for Apprenticeships (19). 

These  initiatives  aimed  to  improve  the  quality  and  effectiveness  of  the  EU’s  measures  to 
promote  youth  employment  and  are  supported  by  EU  funding.  They  implement  amongst 
others  the  first  and  the  fourth  principle  of  the  European  Pillar  of  Social  Rights.  These 
principles  lay  down  the  right  to  ‘quality  and  inclusive  education,  training  and  life-long 
learning’ and the right of young people to ‘continued education, apprenticeship, traineeship or 
a  job  offer  of  good  standing  within  four  months  of  becoming  unemployed  or  leaving 
education’. 

The proposed recommendation is consistent with relevant existing instruments notably: 

• 

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• 

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Directive  (EU)  2019/1152  on  transparent  and  predictable  working  conditions  by 
aiming to improve the transparency of information provided (in writing) to trainees.  

The Occupational Health and Safety (OSH) Framework Directive (20) that lays down 
the main principles for encouraging improvements in the health and safety at work. It 
guarantees  minimum  safety  and  health  requirements  throughout  the  EU.  The 
Framework  Directive  confirms  that,  as  regards  a  secure  workplace,  the  same  rules 
apply to workers and trainees and is accompanied by further directives focusing on 
specific aspects of safety and health at work.  

The  Council  Recommendation  on  access  to  social  protection  for  workers  and  the 
self-employed  (21)  recommends  Member  States  to  ensure  that  both  workers 
(including trainees who are workers) and the self-employed have access to effective 
and  adequate  social  protection.  This  Recommendation  covers  unemployment, 
sickness  and health care, maternity and paternity, invalidity,  old-age and survivors’ 
benefits and benefits in respect of accidents at work and occupational diseases. While 
making  reference  to  this  Recommendation,  the  proposed  recommendation  will 

COM (2024) 1 final.  
COM (2020) 276 final. 
OJ C 372, 4.11.2020, p. 1–9. 
OJ C 417, 2.12.2020, p. 1–16. 
https://ec.europa.eu/social/main.jsp?catId=1147.  
OJ L 183, 29.6.1989, p. 1–8. 
OJ C 387, 15.11.2019, p. 1–8. 

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encourage ensuring access to adequate social protection for all trainees, in line with 
national legislation.   

• 

The  Council  Directive  establishing  a  general  framework  for  equal  treatment  in 
employment  and  occupation  (22)  lays  down  a  general  framework  for  combating 
discrimination  on  the  grounds  of  religion  or  belief,  disability,  age  or  sexual 
orientation as regards employment and occupation, with a view to putting into effect 
in the Member States the principle of equal treatment.  

The objectives  of the proposed recommendation on equal  opportunities and the  inclusion of 
groups  in  vulnerable  situations,  including  persons  with  disabilities,  are  in  line  with  the  EU 
Charter  of  Fundamental  Rights,  with  principles  3  and  17  of  the  European  Pillar  of  Social 
Rights, and the 2021-2030 Strategy for the Rights of Persons with disabilities. 

The proposed recommendation can also help contribute to address the employment objective 
of the EU Roma strategic framework 2020-2030 (23) to ensure that by 2030, the gap in Roma 
NEET rate is cut by at least half. It is consistent with the Council Recommendation on Roma 
equality, inclusion and participation (24), in particular under its chapter 8 on access to quality 
and sustainable employment for Roma. 

The proposed measures facilitating cross-border mobility are in line with the objectives of the 
Erasmus+  programme,  which  offers  transnational  and  international  learning  mobility 
opportunities, including for trainees. 

Moreover, the proposed recommendation is consistent with the Council Recommendation of 
15  March  2018  on  a  European  Framework  for  Quality  and  Effective  Apprenticeships  (25), 
which  sets  out  14  key  criteria  to  define  quality  and  effective  apprenticeships,  ensuring  both 
the development of job-related skills and the personal development of apprentices. According 
to  this  Recommendation, apprenticeships are formal  VET  schemes that  combine learning in 
education or training institutions with substantial work-based learning in companies and other 
workplaces.  They  lead  to  nationally  recognised  qualifications,  are  based  on  an  agreement 
defining the rights and obligations of the apprentice, the employer and, where appropriate, the 
vocational education and training institution, and with the apprentice being paid or otherwise 
compensated  for  the  work-based  component.  Apprenticeships  refer  to  full  programmes 
leading to a qualification, where apprentices ideally spend at least half of the apprenticeship at 
the  workplace.  By  contrast,  traineeships  that  are  part  of  formal  education  and  training 
curricula  refer  to  a  limited  work-based  learning  experience  embedded  in  an  education  and 
training  programme.  Hence,  apprenticeships  tend  to  be  longer  than  traineeships.  As 
traineeships and apprenticeships vary significantly across Member States, Member States are 
encouraged  to  assess  which  of  the  two  quality  frameworks  applies  to  VET  work-based 
learning  experiences,  depending  on  their  national  and  regional  specific  features.  To  ensure 
that all learners in work-based learning receive the highest level of protection, Member States 
are encouraged to apply the framework conditions which are more protective among the two 
frameworks, in line with national circumstances.  

Furthermore,  the  proposed  recommendation  addresses  the  views  of  the  European  Court  of 
Auditors.  The  Court  noted  in  its  review,  ‘EU  actions  addressing  traineeships  for  young 

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OJ L 303, 2.12.2000, p. 16–22. 
COM(2020) 620 final. Available online. 
OJ C 93, 19.3.2021, p. 1–14. 
OJ C 153, 2.5.2018, p. 1–6. 

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people’ (26), that EU guidance on quality traineeships is not applied consistently by Member 
States and that there may be unequal opportunities for traineeships and the access to them. 

• 

Consistency with other Union policies 

The  proposal  is  consistent  with  recent  EU  policies  that  aim  at  empowering  people  through 
education, training and skills. The European Skills Agenda (27) seeks to strengthen the EU’s 
sustainable competitiveness, ensure social fairness and support young people’s resilience.  

The proposal is also consistent with the proposal for a Council Recommendation ‘Europe on 
the  Move’  –  learning  mobility  opportunities  for  everyone  of  15  November  2023  (28).  This 
aims  at  making  learning  opportunities  across  the  EU  more  accessible  for  all  young  people, 
including  young  people  with  fewer  opportunities,  such  as  persons  with  disabilities.  It  also 
promotes  the  attractiveness  of  the  EU  as  a  learning  destination  for  talents  from  outside  the 
EU. 

Financial investments in upskilling and reskilling are at the heart of the European Social Fund 
Plus  (ESF+),  the  Recovery  and  Resilience  Facility  (RRF),  the  Just  Transition  Fund  and 
Erasmus+  and  the  Digital  Europe  Programme.  Skills  development  is  also  supported  by  the 
European  Regional  Development  Fund  (ERDF)  investments  in  education  and  training 
infrastructure  and  equipment.  The  proposed  recommendation  reflects  the  objectives  of  the 
ESF+  that  support  Member  States  and  regions  in  their  endeavours  to  ensure  equal  access  to 
training and skills development opportunities and increase the employability of the European 
workforce, in particular young people. It supports the objectives of the RRF, in particular its 
pillars on policies for the next generation. The proposed recommendation is also in line with 
the  aim  of  the  Just  Transition  Fund  to  support  a  fair  transition  towards  a  climate-neutral 
economy, focusing on the most affected regions. 

Furthermore,  its  objectives  are  consistent  with  those  of  the  ALMA  (Aim,  Learn,  Master, 
Achieve)  initiative,  which  is  funded  by  the  ESF+  and  aims  to  help  disadvantaged  young 
people not in employment, education or training (NEETs) integrate into society by easing their 
way  back  into  education,  training  or  employment.  The  Technical  Support  Instrument  offers 
Member States, upon request, tailor-made expertise to reform and improve learning mobility, 
particularly  through  Flagship  initiatives  focusing  on  attracting  talent,  youth  education  and 
skills.  Finding  skilled  staff  is  a  challenge  for  an  increasing  number  of  small  and  medium 
enterprises (SMEs), which is also highlighted in the SME Strategy for a sustainable and digital 
Europe  (29).  The  Strategy  stresses  that  the  EU  can  further  help  address  these  challenges, 
facilitating access to training and helping match SMEs’ demand for talents with labour market 
supply. The proposal will complement this approach. The proposal also is consistent with the 
Net-Zero Industry Act, in particular the proposed setting up of European skills academies, by 
contributing  to  a  skilled  workforce  through  quality  traineeships  that  can  help  address  skills 
shortages and mismatches. This should alleviate the net-zero technology industries’ need for 
skills. 

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29 

Available online. 
COM(2020) 274 final. 
COM(2023) 719 final. 2023/0405(NLE). 
Communication  from  the  Commission  “An  SME  Strategy  for  a  sustainable  and  digital  Europe”, 
COM/2020/103 final. 

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This initiative is also one of the actions set out in the Commission’s action plan on skills and 
labour shortages in the EU (30). 

2. 

• 

LEGAL BASIS, SUBSIDIARITY AND PROPORTIONALITY 

Legal basis 

The proposal is based on Articles 153(1)(b), 165(4), 166(4) and 292 TFEU. 

Under  Article  153(1)(b)  TFEU,  the  EU  must  support  and  complement  Member  States’ 
activities in the field of working conditions. 

Under Article 165 TFEU, the EU must contribute to the development of quality education by 
encouraging  cooperation  between  Member  States  and,  if  necessary,  by  supporting  and 
supplementing their action, while fully respecting the responsibility of the Member States for 
the  content  of  teaching  and  the  organisation  of  education  systems  and  their  cultural  and 
linguistic diversity.  Under paragraph 4 of Article 165 TFEU,  harmonisation  of the laws and 
regulations  of  the  Member  States  is  excluded,  while  the  Council,  on  a  proposal  from  the 
Commission, can adopt recommendations. 

Under Article 166 TFEU, the  EU must  implement  a vocational  training policy  that supports 
and supplements the action of the Member States, while fully respecting the responsibility of 
the Member States for the content and organisation of vocational training. Under paragraph 4 
of  Article  166  TFEU,  harmonisation  of  the  laws  and  regulations  of  the  Member  States  is 
the  Commission,  can  adopt 
excluded,  while 
recommendations. 

the  Council,  on  a  proposal 

from 

Under  Article  292  TFEU,  the  Council  can  adopt  recommendations  on  the  basis  of  a 
Commission proposal in areas under EU competence. 

• 

Subsidiarity (for non-exclusive competence) 

In its work towards the development of quality education and training and the implementation 
of  a  vocational  training  policy,  the  EU  is  responsible  for  encouraging  cooperation  between 
Member States, supporting  and supplementing  their action where necessary.  In this context, 
setting out a common understanding of what constitutes quality traineeships across the EU is 
a task that can only be addressed at EU level. 

A reinforced Quality Framework for Traineeships will support and supplement national action 
in  this  area  in  line  with  Articles  165,  166  and  153  TFEU.  This  initiative  applies  the 
subsidiarity  principle  by  fully  taking  into  account  that  education  and  training  systems  are  a 
national competence, while the EU may support and complement national policies on working 
conditions.  The  initiative  fully  respects  the  diversity  of  national  traineeship  systems  and 
proposes a set of common criteria to underpin those different schemes, ensuring benefits for 
both the trainee (regardless of their employment status) and traineeship providers. 

The initiative will improve the transparency and mutual understanding of traineeship systems, 
in particular, the quality of traineeships, across the EU. This may also have a positive impact 
on  cross-border  mobility  of  trainees  as  a  coordinated  approach  at  EU  level  would  ensure 
synergies and cooperation, maximising positive spillovers. 

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COM(2024)131. 

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Moreover, providing guidelines at EU level contributes to creating a shared understanding of 
how the quality of traineeships can be improved. This may also help Member States in their 
use of the European Structural and Investment Funds, in particular the European Social Fund+ 
and the Recovery and Resilience Facility, addressing youth unemployment and inactivity. 

• 

Proportionality 

The  actions  proposed  in  the  proposed  recommendation  are  proportionate  to  the  objectives 
being  pursued.  The  proposal  will  support  the  reform  processes  launched  by  individual 
countries on traineeships and will complement Member States’ efforts in this area as part of 
the European Semester framework of economic Governance. The proposal respects Member 
States’  practices  and  the  diversity  of  their  systems.  It  allows  for  a  differentiated  approach 
reflecting Member States’ different economic, financial and social situations and the diverse 
labour  market  conditions.  Using  existing  monitoring  mechanisms  under  the  European 
Semester will ensure that no additional administrative burden is created. 

• 

Choice of the instrument 

The  proposed  instrument  is  a  Council  Recommendation.  This  respects  the  principles  of 
subsidiarity and proportionality. It builds on the existing body of EU law and is in line  with 
the  type  of  instruments  available  for  EU  action  in  the  areas  of  education  and  training  and 
employment.  As  a  legal  instrument,  it  signals  the  commitment  of  Member  States  to  the 
measures  laid  down  in  this  recommendation  and  provides  a  strong  political  basis  for 
cooperation at EU level in this area. It also fully respects Member States’ competence in the 
field of education and training and social policies. 

3. 

RESULTS 
CONSULTATIONS AND IMPACT ASSESSMENTS 

EX-POST 

EVALUATIONS, 

OF 

STAKEHOLDER 

Ex-post evaluations/fitness checks of existing legislation 

• 
An  evaluation  (31)  of  the  2014  Council  Recommendation  on  a  Quality  Framework  for 
Traineeships  was  carried  out  in  2022-2023.  It  found  that  traineeships  continue  to  be  an 
important  pathway for young people to  enter the labour market.  Quality traineeships, which 
are  those  that  reflect  the  principles  of  the  QFT,  contribute  to  increasing  employability  and 
help employers attract, train and retain staff. 

In terms of effectiveness, the QFT principles that were most likely to have a positive impact 
on labour market integration of young people were the setting out of learning and educational 
objectives and the written agreement. However,  actual progress  in  the take-up of its quality 
principles  in  national  legislation  was  moderate.  Since  2014,  14  Member  States  introduced 
changes (either to OMTs or ALMP traineeships or both), integrating the quality principles of 
the  QFT  in  their  legislative  or  policy  frameworks.  Such  changes  were  more  prevalent  in 
national  legislation  governing  ALMP  traineeships  (identified  in  12  Member  States)  than 
OMTs (identified in five Member States). Furthermore, while the prevalence of specific legal 
provisions as well as their conformity with the principles of the QFT were found to be high 
for ALMP traineeships, they were more limited for OMTs. Overall, a slight improvement in 
terms of conformity was observed for OMTs with four Member States fully/mostly aligned in 
2016  compared  to  seven  Member  States  in  2021.  A  larger  improvement  was  observed  for 
ALMP traineeships, with 18 Member States fully/mostly in conformity in 2021 versus 15 in 

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2016.  Room  for  improvement  was  identified  in  the  actual  application  of  the  QFT  on  the 
ground and its monitoring and enforcement. As for the QFT facilitating cross-border mobility 
of trainees in the EU, there were indications that the number of cross-border traineeships had 
increased,  but  young  people  still  faced  difficulties  participating  in  them  due  to  a  lack  of 
financial  means  and  the  unavailability  of  practical  information.  The  use  of  the  European 
Employment Services (EURES) as a source of information was found to be limited. 

The QFT provided added value as a reference point at EU level for Member States’ regulatory 
action on the quality  of  traineeships. This  was particularly  the case for  Member States with 
less  developed  traineeship  systems,  where  the  QFT  helped  foster  policy  and  legislative 
changes at national level. 

As  for  efficiency,  though  the  evaluation  lacked  quantitative  evidence  on  costs  and  benefits, 
stakeholders generally perceived the cost related to implementing the QFT as proportionate to 
the  benefits.  Benefits  for  employers  included  a  better  understanding  of  traineeship  quality, 
reputational advantages, increased attractiveness to young talent, and a more sustainable way 
to  invest  in  potential  future  workers.  However,  the  implementation  of  the  QFT  could  have 
been less cost effective for small and micro enterprises than for larger firms as costs for those 
businesses (due to  limited human and financial  resources) may have been higher relative to 
the  benefits.  Benefits  of  the  QFT  for  trainees  included  improved  working  conditions  and 
better training and learning content, which increased their chances of getting regular jobs. 

The QFT was found to be coherent with other EU level initiatives, strategies, programmes and 
funding  instruments.  At  national  and  regional  level,  a  higher  level  of  coherence  was  found 
with measures on ALMP traineeships than with those on OMTs. Despite the many similarities 
in  quality  principles,  the  European  framework  for  quality  and  effective  apprenticeships 
(EFQEA)(32) was perceived as leading to a greater involvement of stakeholders (e.g. through 
dedicated networks). The EFQEA was also viewed as having higher and more specific quality 
objectives  and  more  benefits  because  stronger  language  was  used  in  the  EFQEA 
recommendation and apprenticeships are often more regulated on a tripartite basis in Member 
States. 

Some respondents (particularly employers) considered that the QFT should remain ‘as is’ as 
they  deem  it  sufficiently  relevant  in  addressing  trainees’  needs.  However,  various 
stakeholders  considered  that  the  relevance  of  the  QFT  could  be  further  strengthened,  in 
particular, when it comes to pay and social protection for trainees and outreach to as well as 
access  for  groups  in  vulnerable  situations.  In  addition,  some  stakeholders  considered  there 
was  a  need  for  the  QFT  to  address  the  challenges  of  remote  working  and  guidance  and 
mentorship in that context. Furthermore, some stakeholders suggested adding traineeships that 
are  part  of  formal  education  and  training  to  the  scope  of  the  QFT.  Some  stakeholders  also 
considered that to ease the transition of a young trainee to a stable job, the QFT could place 
more emphasis on post-placement support. As for the non-binding nature of the QFT, views 
diverged  on  whether  this  is  appropriate  for  fully  reaching  the  QFT  objectives.  On  the  one 
hand, some (notably youth organisations and trade unions) argued for a binding instrument to 
increase  the  effectiveness  of  the  QFT.  On  the  other  hand,  others  (especially  employers  and 
national  authorities)  argued  that,  given  the  differences  in  national  circumstances  and  legal 
limitations at EU level, the QFT’s non-binding nature gave an adequate and flexible reference 
framework for national regulations. 

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• 

Stakeholder consultations 

Specific  consultation  activities  took  place  in  2022  as  part  of  the  Commission’s  2023 
evaluation of the QFT (33), in particular through a public consultation survey. The evaluation 
also  included  targeted  consultations  of  national  and  regional  authorities  responsible  for 
education,  training  and  employment  policies,  social  partners,  education  and  training 
providers,  academic  experts  working  on  labour  market  issues,  organisations  representing 
young people, young (former, current and potential future) trainees and other stakeholders at 
EU,  national  and  regional  level.  To  reach  all  these  stakeholders,  different  consultation 
activities  and  methods  were  used,  such  as  interviews,  targeted  consultation  meetings,  a 
targeted trainees survey and case studies. 

A two-stage consultation of the EU social partners under Article 154 TFEU was carried out 
for this proposal. During the first stage, which took place between 11 July and 15 September 
2023,  social  partners  were  consulted  on  the  need  and  possible  direction  of  EU  action  (34). 
During  the  second  stage,  between  28  September  and  9  November  2023,  the  Commission 
consulted  social  partners  on  the  objectives  and  potential  legal  avenues  for  EU  action  (35). 
Trade unions welcomed the Commission’s intention to update the QFT. They considered that, 
although the principles of the QFT remained relevant, trainees needed binding protection (in 
the form of a directive) to ensure fair compensation, working conditions and social protection. 
This directive should ensure access to all rights enjoyed by regular workers under existing EU 
legislation. Trade unions stressed that the main objective of EU action must be to set binding 
minimum  standards  for  traineeships  in  the  EU  and  to  create  a  level  playing  field  that 
discourages abuse. Employers considered that the principles of the 2014 QFT remain relevant. 
In their opinion, a stronger focus should be placed on its implementation and monitoring, but 
in  their  view  a  revised  Council  Recommendation  would  strike  the  right  balance  between 
promoting  minimum  standards  and  preserving  flexibility.  The  objectives  to  address  the 
problematic use of, improve the quality of and foster access to traineeships were supported by 
employers.  Employers  also  highlighted  the  lack  of  data,  in  particular  on  open-market 
traineeships,  and  the  link  between  pay  and  the  quality  of  traineeships.  There  was  no 
agreement among social partners to enter into negotiations to conclude an agreement at Union 
level in accordance with Article 155 TFEU.  

Furthermore, as part of the study exploring the context, challenges and possible solutions in 
relation to the quality of traineeships in the EU, an online survey was conducted with national 
stakeholders.  This  aimed  to  gather  information  on  the  current  practices  of  businesses 
regarding  traineeships  and  identify  good  practices  implemented  in  Member  States  and  their 
impact on the quality of traineeships. The survey ran from 15 June to 8 September 2023 and 
was targeted at national public authorities, national business/employer associations, individual 
businesses, national trade unions, national youth organisations, civil society organisations and 
educational institutions. Targeted interviews with EU-level stakeholders were also carried out. 

A dedicated ‘SME Panel’ survey was conducted by the Directorate General  for Employment, 
Social  Affairs  and  Inclusion  (DG  EMPL),  the  Directorate  General  for  Internal  Market, 
Industry, Entrepreneurship and SMEs (DG GROW), the European Innovation Council and the 
SMEs Executive Agency (EISMEA) and with the support of the Enterprise Europe Network 
between 12 October and 9 November 2023. 

33 
34 
35 

Available online.  
Available online.  
Available online.  

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The  Flash  Eurobarometer  survey  (523)  (36)  looked  into  young  people’s  perceptions  of  their 
integration into the labour market, with a particular focus on traineeships. Between 15 and 24 
March 2023, 26 334 people aged between 18 and 35 from all Member States were surveyed 
online. 

• 

Collection and use of expertise 

The proposed recommendation draws on several  studies carried out to underpin the analysis 
of the initiative: 

• 

• 

• 

a study commissioned from  external  experts, of  which the preliminary  results were 
used: "Study exploring the context, challenges and possible solution in relation to the 
quality  of  traineeships  in  the  EU"  by  a  consortium  of  Ernst  &  Young  (EY),  the 
Centre of European Policy Studies (CEPS) and Open Evidence (forthcoming) 

an  external  study  supporting  the  evaluation  of  the  Quality  Framework  for 
Traineeships, Final Report, January 2023 (37) 

the  Flash  Eurobarometer  survey  on  the  perception  of  young  people  regarding  their 
integration into the labour market, with a particular focus on traineeships (38) 

The European Parliament’s 2023 legislative own-initiative resolution on quality traineeships 
in the EU was also taken into account, in conjunction with the relevant European added value 
Assessment of Parliament’s research service (39). 

• 

Impact assessment 

In  line  with  its  Better  Regulation  policy,  the  Commission  carried  out  an  impact  assessment 
(40). This gave a structured analysis of the policy problems, corresponding policy objectives 
and  policy  options  and  assessed  their  impact.  It  considered  the  subsidiarity,  effectiveness, 
efficiency,  coherence  and  proportionality  of  the  identified  options  and  how  to  monitor  and 
evaluate the initiative in the future. This work was supported by a structured consultation in 
the Commission via an inter-service steering group (41) and the forthcoming “Study exploring 
the  context,  challenges  and  possible  solution  in  relation  to  the  quality  of traineeships  in  the 
EU” referred to above. 

The impact  assessment identified three problems:  (1) the problematic use of traineeships by 
traineeship  providers,  (2)  the  poor  quality  of  traineeships  and  (3)  unequal  access  to 
traineeships.  The  impact  assessment  examined  three  policy  options,  which  combined  both 
legislative and non-legislative measures addressing the objectives of the initiative in terms of 
enforcing  applicable  rights  of  trainees,  preventing  the  problematic  use  of  traineeships, 
ensuring fair working conditions, improving the learning content, and improving the access to 
and the inclusiveness of traineeships. The assessment of the impact of the options also took 

36 
37 
38 
39 
40 

41 

Available online. 
Available online.   
Available online.  
Available online. 
Commission Staff Working Document, Impact Assessment Report (2024), Accompanying the proposal 
for  a  Directive  of  the  European  Parliament  and  of  the  Council  on  improving  and  enforcing  working 
conditions  of  trainees  and  combating  employment  relationships  disguised  as  traineeships  and  the 
proposal  for  a  Council  Recommendation  on  a  reinforced  Quality  Framework  for  Traineeships, 
forthcoming. 
Including  the  Legal  Service, SG,  DG  CNECT,  DG  EAC,  JRC,  DG  COMM,  DG  GROW,  DG  JUST, 
DG REGIO and DG AGRI. 

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into  consideration  the  potential  unintended  consequences  of  the  different  policy  options, 
including on the offer of traineeships. 

The  preferred  policy  option  identified  in  the  impact  assessment  is  a  package  made  up  of  a 
directive  applying  to  trainees  who  are  workers  under  EU  law  and  an  updated  Council 
recommendation  covering  all  trainees.  This  package  is  expected  to  bring  social  benefits  to 
trainees by reducing problematic and poor-quality traineeships through equal treatment, fairer 
pay and adequate social protection, and by improving access to traineeships, in particular for 
persons  in  vulnerable  situations,  including  persons  with  disabilities,  those  residing  in  rural, 
remote  and  outermost  regions,  those  with  a  disadvantaged  socio-economic  and/or  migrant 
background, those from the Roma community, and those with lower educational attainment. 
The preferred option is expected to result in economic benefits for traineeship providers, such 
as fairer market competition, productivity and competitiveness gains due to a more skilled and 
diverse workforce and lower search, matching and recruitment costs. As for costs associated 
with the preferred option, these relate to a possible increase in labour costs, adjustment costs 
and potential costs resulting from administrative or judicial procedures. National budgets and 
administrations  are  expected  to  benefit  from  increased  tax  and  social  security  receipts  and 
reduced social protection and activation spending. 

The impact assessment was first discussed with the Commission’s Regulatory Scrutiny Board 
on  13  December  2023.  On  1  February  2024,  a  revised  impact  assessment  Report  was 
submitted  to  the  Board.  On  22  February  2024,  the  Board  issued  a  positive  opinion  with 
reservations  (42). The  remaining  comments  were  subsequently  addressed,  by  specifying 
further  the  limitations  of  the  used  data,  strengthening  the  discussions  on  level  playing  field 
and competition issues and providing additional targeted clarifications on the description and 
assessment of the policy options. 

• 

Fundamental rights 

The  Charter  of  Fundamental  Rights  of  the  European  Union  protects  a  broad  range  of 
employment rights. The objectives of this proposal are in line with the Charter. The proposed 
recommendation  is  expected  to  contribute  to  ensuring  the  right  to  equality  before  the  law 
(Article 20 of the Charter), the right to fair working conditions (Article 31), the protection of 
young  people  at  work  (Article  32),  access  to  adequate  social  protection  (Article  34)  and 
healthcare (Article 35). 

4. 

BUDGETARY IMPLICATIONS 

The proposed recommendation does not require additional EU budget or staff resources. 

5. 

• 

OTHER ELEMENTS 

Implementation plans and monitoring, evaluation and reporting arrangements 

The  recommendation  proposes  that  Member  States  take  appropriate  measures  to  apply  the 
reinforced  QFT  as  soon  as  possible  and  submit  an  implementation  plan  setting  out  the 
corresponding measures to be taken at national level by [date of adoption + [18 months]. 

42 

Regulatory Scrutiny Board, 2nd Opinion ‘Positive with reservations’ on the impact assessment Quality 
Framework for traineeships of 28 February 2024 (to be published). 

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• 

Explanatory documents (for directives) 

Not applicable. 

• 

Detailed explanation of the specific provisions of the proposal 

The proposed recommendation offers a set of criteria for quality traineeships, while allowing 
flexibility  in  implementation  by  Member  States.  This  enables  them  to  take  into  account  the 
specific nature and different needs of their national traineeship schemes.  

Objective and scope 

Point  1  sets  out  the  objective  of  the  reinforced  framework  to  improve  the  quality  of 
traineeships, in particular learning and training content and working conditions. 

Point  2  explains  the  scope  of  the  reinforced  framework,  which  applies  to  all  trainees, 
regardless of their employment status. It clarifies that, for those trainees who are workers, the 
framework only applies if there are no equivalent or more favourable provisions laid down in 
EU law. 

Written agreement 

Points 3 and 4 recommend that traineeships are based on a written agreement and update the 
contents  of  the  written  agreement  by  recommending  additional  information  on  the  learning 
component, tasks, mentorship arrangements and social protection. 

Learning and working conditions 

Points 5 to 15 set out the learning and working conditions, including the learning and training 
objectives,  fair  pay,  applicable  rights  and  working  conditions  under  applicable  EU  and 
national  law,  the  assignment  of  a  supervisor  and  a  mentor,  conditions  for  remote/hybrid 
traineeships, a reasonable duration (including for repeated/consecutive traineeships), renewal 
and  termination  of  traineeships  and  channels  for  trainees  to  report  malpractice  and  poor 
conditions.  They  also  set  out  that  traineeship  providers  cannot  require  candidates  to  have 
previous work experience. 

Social protection 

Point 16 recommends access to adequate social protection in line with national practices and 
taking into consideration Council Recommendation on access to social protection for workers 
and the self-employed. 

Recognition of traineeships 

Point 17 updates the proper recognition of traineeships by adding that such recognition, where 
appropriate and if possible, should be produced in a digital format. 

Transparency requirements 

Points  18  to  20  set  out  transparency  requirements  and  adds  that  vacancy  notices  and 
advertisements  should  also  provide  information  on  the  level  of  pay,  working  conditions, 
social protection coverage and the expected tasks. 

Inclusive traineeships 

Points 21 to 24 recommend measures on inclusive traineeships (including by ensuring equal 
treatment and non-discrimination and by improving access and outreach to those in vulnerable 
situations),  neutral  language  in  vacancy  notices  /  advertisements,  raising  awareness  and 
changes, where relevant, to ensure accessibility, including for those in vulnerable situations, 
in particular (candidate) trainees with disabilities. 

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Cross-border traineeships 

Points 25 to 29 update the measures aimed at facilitating cross-border traineeships, calling for 
practical  guidance  and  information  on  cross-border  traineeships  through  EURES  and  by 
encouraging the application of the principles of the reinforced framework, where applicable, 
in traineeship mobility agreements with hosting organisations outside the EU. 

Additional traineeship support 

Point  30  recommends  additional  traineeship  support,  in  particular  by  providing  career 
guidance and network opportunities. 

Framework conditions 

Points  31  to  33  set  out  the  elements  regarding  the  framework  conditions,  including  on  the 
involvement of social partners, employment services, education and training institutions and 
other stakeholders. It is also recommended to ensure that workers’ representatives may defend 
the rights of trainees. 

Applying the reinforced quality framework 

Points  34  to  35  provide  recommendations  on  applying  the  reinforced  QFT,  including  for 
Member  States  to  submit  an  implementation  plan,  and  by  envisaging  financial  and  non-
financial support to traineeship providers, in particular SMEs. 

Support to increase trainees’ employability 

Points 36 to 37 set out support measures to increase trainees’ employability and recommend 
giving  incentives  to  traineeship  providers  to  propose  a  job  after  a  traineeship  and  use  EU 
funds for traineeships that are in line with the principles of the reinforced Framework. 

Follow-up 

Point 38 recommends Member States and the Commission work jointly on the collection of 
data. 

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2024/0069 (NLE) 

Proposal for a 

COUNCIL RECOMMENDATION 

on a reinforced Quality Framework for Traineeships 

THE COUNCIL OF THE EUROPEAN UNION, 

Having  regard  to  the  Treaty  on  the  Functioning  of  the  European  Union,  and  in  particular 
Article 292, in conjunction with Articles 153(1)(b), 165(4) and 166(4) thereof, 

Having regard to the proposal from the European Commission, 

Whereas: 

(1) 

(2) 

(3) 

(4) 

(5) 

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44 
45 
46 

In March 2014, the Council adopted the Recommendation on a Quality Framework for 
Traineeships  (43)  (‘2014  Recommendation)  to  provide  Union-wide  quality  standards 
for traineeships. It recommended 21 principles for traineeships to improve the quality 
of traineeships, in  particular to  ensure high  quality  learning and training  content and 
adequate working conditions to support education-to-work transition and increase the 
employability  of  trainees.  The  2014  Recommendation  covers  all  traineeships  except 
for those that are part of curricula of formal education and training and those regulated 
under national law and the completion of which is a mandatory requirement to access 
a specific profession. 

The  Council  Recommendation  on  a  European  Framework  for  Quality  and  Effective 
Apprenticeships  (44)  contains  14  criteria  for  quality  and  effective  apprenticeships 
aiming  to  ensure  that  apprenticeship  schemes  are  responsive  to  labour  market  needs 
and provide benefits to both learners and employers. These include criteria for learning 
and working conditions and criteria for framework conditions. 
The reinforced Youth Guarantee (45) aims at ensuring that young people under the age 
of 30 receive a good quality offer of employment, continued education, apprenticeship 
or  traineeship  within  a  period  of  four  months  of  becoming  unemployed  or  leaving 
education.  The  2014  Recommendation  has  served  as  an  important  reference  point  to 
measure the quality of traineeships offers under the reinforced Youth Guarantee. 

Facilitating the transition to quality employment is necessary for achieving the Union 
headline target of a 78% employment rate of the population aged 20-64 by 2030 (46). 

Traineeships  can  help  young  people  gain  practical  and  professional  experience, 
improve their employability, and facilitate their transition into stable employment. As 
such,  traineeships  constitute  an  important  pathway  to  the  labour  market.  For 
employers, traineeships provide opportunities to attract, train and retain young people. 

OJ C 88, 27.3.2014, p. 1. Available online. 
OJ C 417, 2.12.2020, p. 1–16. 
OJ C 372, 4.11.2020, p. 1–9. 
One of the three EU-level social targets included in the European Pillar of Social Rights Action Plan  
To be achieved by 2030.  

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(6) 

(7) 

(8) 

(9) 

They can reduce the cost of searching for and recruiting skilled staff, when trainees are 
offered a regular position after their traineeship. 

Labour shortages exist in many occupations and at all skills levels. They are expected 
to  increase  with  the  projected  decline  in  the  working  age  population  and  increasing 
demand for several occupations relevant for the green and digital transition. Increasing 
the  labour  market  participation  and  up-and/or  reskilling  of  young  people  could 
contribute  to  alleviating  these  shortages.  Quality  traineeships  can  be  a  useful  up- 
and/or reskilling pathway for persons of any age to acquire practical skills on the job 
to enter the labour market or to take their career in a new direction. 

The  Conference  on  the  Future  of  Europe  put  forward  a  proposal  on  ensuring  that 
young people’s internships and jobs adhere to quality standards, including on pay and 
banning unpaid internships on the labour market and outside formal education (47). 

The  European  Parliament  adopted  a  resolution  pursuant  to  Article  225  TFEU  with 
recommendations to the Commission on quality traineeships in June 2023 (48).  In its 
resolution,  it  called  on  the  Commission  “to  update  and  strengthen  the  2014 
Recommendation and to turn it into a stronger legislative instrument”. It further called 
on the Commission  to  include additional principles in  an updated quality  framework 
for  traineeships.  Specifically,  the  European  Parliament  called  for  the  Commission  to 
“propose a directive on open labour market traineeships, traineeships in the context of 
active labour market policies and traineeships that are a mandatory part of professional 
training, in order to ensure minimum quality standards, including rules on the duration 
of  the  traineeships,  access  to  social  protection  in  accordance  with  national  law  and 
practice  as  well  as  pay  that  ensures  a  decent  standard  of  living  in  order  to  avoid 
exploitative practices”. 

The Commission carried out a two-stage consultation of social partners at Union level 
under  Article  154  TFEU  on  the  need,  objectives  and  legal  avenues  for  a  potential 
action further improving the quality  of traineeships. There was no agreement among 
the  social  partners  to  enter  into  negotiations  with  regard  to  those  matters.  It  is, 
however, important  to  take action at  Union level in  this  area by adapting the current 
framework on traineeships while taking into account the outcomes of the consultation 
of social partners. 

(10)  The Commission  has  extensively  consulted with  stakeholders, including  trainees  and 
youth  organisations,  traineeship  providers,  national  public  authorities,  educational 
institutions, and experts from academia. 

(11)  Furthermore, in 2023, the Commission evaluated the 2014 Recommendation (49) and 
found that quality traineeships, which reflect the principles of that Recommendation, 
contribute to increasing young people’s employability. While the quality principles of 
the  2014  Recommendation  were  considered  still  relevant  and  of  added  value,  the 
evaluation also concluded that the application of those principles and their monitoring 
and  enforcement  needed  to  be  improved.  It  also  found  room  for  strengthening  the 
framework,  including  on  aspects  related  to  pay  and  access  to  social  protection. 
Furthermore,  to  ease  the  transition  to  a  regular  employment  relationship,  more 
emphasis  on  post-placement  support  could  be  provided  by  traineeship  providers.  It 

47 
48 

49 

Conference on the Future of Europe, Report on the final outcome – May 2022. Availabe online.  
European Parliament resolution of 14 June 2023 with recommendations to the Commission on quality 
traineeships in the Union (2020/2005(INL)). Available online. 
Available online.  

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also  found  that  employers  could  be  better  assisted  through  practical  guidance  and 
financial  support  as  well  as  by  linking  such  support  to  the  application  of  the  quality 
principles. 

(12)  The evaluation also identified the need to ensure inclusiveness and improve access to 
traineeships for people in vulnerable situations. In particular, minorities, persons with 
disabilities,  those  residing  in  rural,  remote  and  outermost  regions,  those  with  a 
disadvantaged socio-economic and/or migrant background, the Roma community, and 
those  with  lower  educational  attainment,  face  obstacles  in  accessing  traineeship 
opportunities. Among other obstacles, a barrier for persons with disabilities to access 
traineeships is the lack of traineeship programmes adapted to their needs, for example 
catering for specific accessibility requirements. 

(13)  The  2023  Eurobarometer  survey  (FL523)  (50)  found  that  55%  of  respondents  having 
done  a  traineeship  were  paid  or  financially  compensated,  which  is  an  increase  from 
40%  in  the  2013  Eurobarometer  survey  (FL378)  (51).  Furthermore,  in  2023  33%  of 
respondents  answered  that  they  had  full  (and  28%  of  respondents  partial)  access  to 
social protection (52). 

(14)  This  Recommendation  addresses  the  need  to  reinforce  the  quality  framework  for 
traineeships  as  identified  by  the  evaluation  and  by  various  stakeholders  mentioned 
above. It aims to improve the quality of traineeships, in particular as regards learning 
and training content and working conditions, with the aim of easing the transition from 
education, unemployment or inactivity to work. 

(15)  For  the  purposes  of  this  Recommendation,  traineeships  should  be  understood  as  a 
limited  period  of  work  practice,  which  includes  a  significant  learning  and  training 
component,  undertaken  in  order  to  gain  practical  and  professional  experience  with  a 
view  to  improving  employability  and  facilitating  transition  to  a  regular  employment 
relationship or accessing a profession. Without prejudice to other types of traineeships 
that  may  exist,  the  following  four  types  of  traineeships  have  been  identified:  open 
market  traineeships,  traineeships  that  are  part  of  active  labour  market  policies, 
traineeships that are part of curricula of formal education and training, and traineeships 
that are a mandatory requirement to access a certain profession. 

(16)  Open market traineeships are based on non-mandatory, bilateral agreements between a 
trainee and a traineeship provider (public/private/non-profit) without the involvement 
of a third party and without a formal connection to education or training. 

(17)  Traineeships  as  part  of  active  labour  market  policies  (ALMP)  are  offered  to  the 
inactive  or  unemployed  or  those  at  risk  of  becoming  unemployed,  with  usually  a 
public institution (often an employment service) acting as an intermediary between the 
traineeship provider and the trainee. 

(18)  Traineeships can also be work-based learning placements that are part of curricula of 

formal education and training (school, vocational or higher education and training). 

(19)  National  law  can  also  regulate  certain  traineeships  and  make  their  completion 

mandatory to access a specific profession (e.g., medicine, architecture, etc.). 

50 
51 
52 

Available online. 
Available online. 
The 2013 Eurobarometer survey asked about health insurance coverage (73% of respondents stated they 
were covered), but not about social protection coverage.  

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(20)  This Recommendation applies to all traineeships referred to in recitals (16) to (19). 

(21)  As  traineeships  and  work-based  learning  programmes  in  vocational  education  and 
training as set out in Council Recommendation on a European Framework for Quality 
and  Effective  Apprenticeships  (53)  vary  significantly  across  Member  States,  Member 
States  are  encouraged  to  assess  which  of  the  two  quality  frameworks  applies  to 
vocational education and training (VET) work-based learning experiences, depending 
on  their  national  and  regional  specific  features.  When  doing  so,  to  ensure  that  all 
learners in work-based learning receive the highest level of protection, Member States 
are encouraged to  apply the framework  conditions  which are more protective among 
the two frameworks, in line with national circumstances. 

(22)  The lack of fair pay and access to adequate social protection present barriers to equal 
access to traineeship opportunities. In the absence of an alternative source of income, 
groups  in  vulnerable  situations  tend  to  refrain  from  engaging  in  traineeships,  in 
particular  when  pay  is  absent  or  low,  or  when  additional  costs  are  incurred,  for 
example doing a traineeship in a different region or country. 

(23)  Gaps in access to social protection can put the welfare and (mental) health of trainees 
at  risk,  contribute  to  their  economic  uncertainty,  precariousness  and  risk  of  poverty. 
This risk is especially high for trainees from socio-economically disadvantaged groups 
and/or  in  other  vulnerable  situations.  Trainees  may  face  barriers  in  accessing  social 
rights and benefits notably due to their short contributory history. Furthermore, most 
social  protection  schemes  (with  the  exception  of  healthcare  benefits)  require  an 
employment status, which excludes trainees who are not considered workers. 

(24)  A prolonged duration or accumulation of multiple traineeships can delay the access to 
regular employment relationships for the individual trainees concerned. They can also 
be indicative of traineeships being used to replace regular employment relationships. 

(25)  A prolonged duration of a traineeship could be warranted if justified by the nature and 
purpose  of  the  specific  type  of  traineeship.  Examples  of  exceptions  could  be 
traineeships  whose  completion  is  a  mandatory  requirement  to  access  a  specific 
profession, where the trajectory to acquire the necessary knowledge, competences and 
experience warrants a longer traineeship experience. Certain traineeships that are part 
of  active  labour  market  policies  aimed  at  the  integration  of  persons  in  a  vulnerable 
situation could also benefit from a longer duration. Some traineeships that are part of 
curricula  of  formal  education  and  training  may  have  a  longer  duration  for  reasons 
linked to the curricula. 

(26)  Repeated  traineeships,  and  practices  aimed  at  replacing  jobs  with  employment 
relationships  disguised  as  traineeships,  could  be  induced  by  traineeship  providers 
requesting  previous  experience  in  the  same  or  similar  field  of  activity  in  vacancy 
notices.  The  overall  duration  of  traineeships  is  sometimes  also  prolonged  through 
repeated, including consecutive, traineeships with the same employer. Such practices 
may  be  another  indication  of  an  employment  relationship  disguised  as  traineeship. 
However, there may be objective grounds based on which traineeship providers may 
require  previous  work  experience  from  (candidate)  trainees.  Such  instances  could 
entail an equivalent period of previous work experiences being an alternative to having 
a  degree  in  a  certain  field  of  activity  or  expertise.  A  trajectory  to  access  a  specific 

53 

OJ C 417, 2.12.2020, p. 1–16. 

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profession may also warrant having previous work experience before embarking  in a 
more specialised traineeship. 

(27)  The  evaluation  highlighted  the  need  to  strengthen  the  support  to  trainees  during  the 
traineeship  through  appropriate  mentorship.  Therefore,  the  role  of  the  supervisor 
should  be  complemented  with  a  mentor,  whose  role  would  encompass  advising, 
coaching  and supporting the trainee with a view on personal development as well as 
integration 
the 
organisational needs and size of the traineeship provider. 

the  work  environment,  wherever  possible  considering 

into 

(28)  Since  the  COVID-19  pandemic,  the  prevalence  of  remote  and  hybrid  working 
arrangements  has  increased.  To  ensure  the  quality  and  accessibility  of  remote  and 
hybrid  traineeships,  adaptations  to  the  increased  practice  of  telework  are  needed  in 
terms  of  appropriate  working  environment  (including  equipment)  and  work 
organisation. The latter comprises guidance, mentorship, and tasks suited for a remote 
and hybrid way of working. 

(29)  To increase the transparency of information on a traineeship opportunity, traineeship 
providers should be encouraged to include information on the terms and conditions of 
the traineeship, in particular on the level of pay, working conditions, the coverage of 
social  protection,  including  health  and  accident  insurance,  the  expected  tasks  and 
learning  and  training  component  in  the  vacancy  notices  and  advertisements  for 
traineeships  possibly  by  including  a  link  to  a  website  containing  this  information 
therein. 

(30)  Traineeship  providers  should  be  encouraged  to  provide  information  on  recruitment 
policies, in particular on the share of trainees recruited. This is calculated by dividing 
the number of trainees that were hired (following the completion of the traineeship) to 
fill  a  regular  employment  position  by  the  total  number  of  trainees  at  the  same 
establishment in the same year. 

(31)  Employment services and other providers of career guidance should be encouraged to 
apply  the  same  transparency  requirements  as  traineeship  providers  when  providing 
that 
information  on 
employment services and other providers of career guidance may not be aware of all 
the  information  elements  listed  under  the  transparency  requirements  and  may  be 
dependent on the traineeship providers’ willingness to share such information. 

traineeship  opportunities.  It 

is  however  acknowledged 

(32)  To  ensure  equal  access  for  groups  in  vulnerable  situations,  strengthened  outreach  to 
such groups is needed, such as through targeted communication and awareness-raising 
strategies. To ensure the effectiveness of such outreach strategies, it is key to involve 
relevant  stakeholders  such  as  employment  services  and  education  and  training 
institutions  and  to  tailor  the  communication  and  information  tools  used  to  reach  the 
widest range of people possible, including those with certain disabilities (e.g. adapted 
and easy to read websites). 

(33)  To ensure the application of the Recommendation, support to  employers needs to  be 
strengthened  through  practical  guidance  and  financial  support,  the  latter  of  which 
could  depend  on  the  condition  that  the  traineeships  offered  adhere  to  the  quality 
principles of this Recommendation. 

(34)  Cross-border  traineeships  can  be  particularly  valuable  as  trainees  may  learn  another 
language, are exposed to a new environment or culture and can thus acquire relevant 

EN 

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transversal  skills.  There  are  indications  that  cross-border  mobility  of  trainees  has 
increased  (54),  yet  young  people  still  face  difficulties  in  accessing  cross-border 
traineeships  due  to  a  lack  of  financial  means  and  the  unavailability  of  relevant  (and 
sufficient)  information.  More  concrete  and  practical  information  on  cross-border 
traineeships, such as on EURES, is needed to improve accessibility. 

(35)  Channels  to  report  malpractice  and  poor  working  conditions  can  support  trainees  in 
enforcing  their  labour  rights.  In  addition,  allowing  trainees  to  have  their  rights 
defended by workers’ representations would strengthen their position. 

(36)  Member  States'  programmes  promoting  and  offering  quality  traineeships  can  be 
financially supported by the European Funds. The European Social Fund Plus (ESF+) 
established by Regulation (EU) 2021/1057 (55), the Recovery and Resilience  Facility 
(RRF)  established  by  Regulation  (EU)  2021/241  (56)  for  eligible  reforms  and 
investments  foreseen  in  Member  States’  recovery  and  resilience  plans  for  delivery 
during  the  Facility’s  lifetime  until  the  end  of  2026,  the  Just  Transition  Fund 
established by Regulation (EU) 2021/1056 (57) and the Technical Support Instrument 
(TSI)  established  by  Regulation  (EU)  2021/240  (58),  could  support  Member  States’ 
implementation of the Recommendation. 

(37)  To ensure consistent approaches among Member States, the Commission has proposed 
a  directive  (COM(2024)  132)  which  lays  down  a  common  framework  of  principles 
and measures to improve and enforce the working conditions of trainees and to combat 
regular employment relationships disguised as traineeships. 

(38)  As far as information to be provided to trainees in the written traineeship agreement is 
concerned,  trainees  who  are  workers  are  entitled  to  the  minimum  requirements  on 
information duties as set out in Directive (EU) 2019/1152 of the European Parliament 
and  of  the  Council  (59).  Insofar  not  covered  by  this  directive,  the  elements  in  this 
recommendation  should  be  taken  into  account  in  addition  to  those  minimum 
requirements for trainees who are workers. 

(39)  The implementation  of this  Recommendation should  not  constitute valid grounds  for 
reducing  the  general  level  of  protection  afforded  to  trainees  covered  by  this 
Recommendation. 

(40)  This  Recommendation  should  avoid  imposing  administrative,  financial  or  legal 
constraints in a way which would hold back the creation or development of small and 
medium-sized  enterprises  (SMEs).  Member  States  are  therefore  invited  to  assess  the 
impact of their policies or reforms on SMEs in order to make sure that SMEs are not 
disproportionately affected, with specific attention be paid to micro-enterprises and the 
administrative burden, and to publish the results of such assessments. 

54 

55 
56 
57 
58 
59 

As shown by the prevalence of cross-border traineeships: an increase from 9% in 2014 to 19% in 2022 
according to the evaluation of the 2014 Council Recommendation, supported by the results of the 2023 
Eurobarometer survey (FL523) with 21% of respondents having done at least one traineeship in another 
EU country. 
OJ L 231, 30.6.2021, p. 21–59. 
OJ L 57, 18.2.2021, p. 17–75. 
OJ L 231, 30.6.2021, p. 1–20. 
OJ L 57, 18.2.2021, p. 1–16. 
OJ L 186, 11.7.2019, p. 105–121. 

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(41)  This  Recommendation  supersedes  Council  Recommendation  of  10  March  2014  on  a 
Quality  Framework  for  Traineeships  which  therefore  should  no  longer  be  applied 
anymore by Member States. 

ACKNOWLEDGES THE COMMISSION’S INTENTION TO 

(42) 

foster  close  cooperation  with  Member  States,  social  partners  and  other  stakeholders 
with a view to swiftly applying this Recommendation. 

(43)  work  with  Member  States,  social  partners,  employment  services,  youth  and  trainee 
organisations,  education  and  training  institutions  and  other  stakeholders  to  promote 
this  Recommendation,  including  through  awareness-raising  on  the  quality  principles 
and benefits of traineeships for young people and traineeship providers. 

(44) 

encourage and support the implementation of this Recommendation, including through 
facilitating  the  exchange  of  best  practices  among  Member  States  and  among 
stakeholders  through  existing  networks,  including  skills  partnerships  under  the  Pact 
for Skills. 

(45) 

support the implementation of this Recommendation through relevant Union funding, 
in  accordance  with  the  relevant  legal  frameworks,  to  increase  the  number  of  quality 
traineeships. 

(46)  work  jointly  with  Member  States  on  the  collection  of  a  limited  set  of  data  on 
traineeships,  with  a  particular  view  to  monitoring  the  progress  in  applying  this 
Recommendation while being mindful of unnecessary reporting burden. 

(47) 

continue  monitoring  in  cooperation  with  the  Member  States  and  with  the  support  of 
the  Employment  Committee,  the  progress  in  applying  the  reinforced  Quality 
Framework for Traineeships, building on the existing monitoring instruments used in 
the framework of the European Semester. 

(48) 

report  to  the  Council  on  the  progress  in  applying  this  Recommendation  based  on 
information  provided  by  Member  States  within  [three  years]  from  the  date  of  its 
adoption. 

HAS ADOPTED THIS RECOMMENDATION 

Objective and scope 

1.  This  Recommendation  aims  to  improve  the  quality  of  traineeships,  in  particular  as 

regards learning and training content and working conditions, with the aim of easing the 

transition from education, unemployment or inactivity to work. 

2.  This  Recommendation  should cover all trainees, regardless  of their  employment status, 

including trainees who are workers only insofar and to the extent that equivalent or more 

favourable provisions are not laid down in Union law. 

Quality principles 

HEREBY RECOMMENDS THAT MEMBER STATES: 

Written agreement 

3. 

ensure that traineeships are based on a written agreement concluded at the beginning of 

the traineeship between the trainee and the traineeship provider. 

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4. 

ensure that traineeship agreements set out the information elements listed in Article 4 of 

Directive (EU) 2019/1152, the learning and training component, including its objectives, 

the  working  conditions,  the  tasks  to  be  carried  out,  the  arrangements  for  mentorship, 

supervision and evaluation, details on social protection coverage, including with regards 

to coverage for sickness and healthcare as well as for accidents at work and occupational 

diseases,  the  rights  and  obligations  of  the  parties  under  applicable  Union  and  national 

law,  collective  agreements  and  practice,  and,  where  relevant,  the  traineeship  provider's 

policies on confidentiality and the ownership of intellectual property rights. 

Learning and working conditions 

5. 

ensure  that  trainees  are  consulted  when  setting  the  specific  learning  and  training 

objectives  of  the  traineeship  in  order  to  help  trainees  acquire  practical  experience  and 

relevant  skills.  The  tasks  assigned  to  the  trainee  should  enable  these  objectives  to  be 

attained. 

6. 

ensure  that  trainees  are  fairly  paid,  taking  into  account  elements  such  as  the  trainee’s 

tasks  and  responsibilities,  the  intensity  of  the  trainee’s  work,  and  the  weight  of  the 

learning and training component. 

7. 

ensure  that  the  rights  and  working  conditions  of  trainees  under  applicable  Union  and 

national law, including health and safety legislation, limits to maximum weekly working 

time, minimum daily and weekly rest periods and, where applicable, minimum holiday 

entitlements, are respected through effective monitoring and enforcement. 

8. 

ensure that traineeship  providers designate a supervisor for guiding the trainee through 

the assigned tasks, overseeing the activities carried out by the trainee and monitoring and 

assessing their progress. 

9. 

ensure that traineeship providers designate a mentor acting as an advisor to the trainee, 

and  providing  coaching  and  support,  wherever  possible  considering  the  organisational 

needs and size of the traineeship provider. 

10.  ensure  that  traineeship  providers  provide  an  appropriate,  safe  and  healthy  working 

environment,  including  equipment  and  work  organisation  in  the  case  of  remote  and 

hybrid traineeships. 

11.  ensure a reasonable duration of traineeships  that does not exceed six months, except in 

cases where a longer duration is justified by objective grounds  and taking into account 

national practices. In the event of repeated, including consecutive, traineeships with the 

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same employer, ensure that the overall duration of those traineeships does not exceed six 

months, except in cases where a longer duration is justified by objective grounds. 

12.  clarify the circumstances and conditions under which a traineeship may be extended or 

renewed after the end of the initial traineeship. 

13.  ensure that employers do not require candidates for traineeships to have previous work 

experience in the field of activity, except in cases where such requirement is justified by 

objective grounds. 

14.  ensure  the  practice  of  specifying  in  the  traineeship  agreement  that  either  the  trainee  or 

the traineeship provider may terminate it by written communication, providing advance 

notice  of  an  appropriate  duration  in  view  of  the  length  of  the  traineeship  and  relevant 

national practice. 

15.  ensure,  in  cooperation  with  competent  authorities,  channels  for  trainees  to  report 

malpractice and poor working conditions and provide information on those channels. 

Social protection 

16.  ensure  that  trainees  have  access  to  adequate  social  protection,  including  necessary 

coverage in line with national legislation, and taking into account, where applicable, the 

Council Recommendation 8 November 2019 (60). 

Proper recognition of traineeships 

17.  promote  the  recognition  and  validation  of  the  knowledge,  skills  and  competences 

acquired during traineeships  and encourage traineeship  providers to  attest  them, on the 

basis  of  an  assessment,  through  a  certificate,  where  appropriate,  and  if  possible  in  a 

digital format. 

Transparency requirements 

18.  ensure  that  traineeship  providers  include  in  their  vacancy  notices  and  advertisements 

information on the terms and conditions of the traineeship, in particular on the level of 

pay, working conditions, the coverage of social protection, including health and accident 

insurance, the expected tasks and learning and training component. 

19.  encourage  traineeship  providers  to  give  information  on  recruitment  policies,  including 

the share of trainees recruited in recent years. 

60 

Council Recommendation of 8 November 2019 on access to social protection for workers and the self-
employed (OJ C 387, 15.11.2019, p. 1). 

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20.  encourage employment services and other providers of career guidance, when providing 

information on traineeships, to apply the transparency requirements as listed in point 18. 

Inclusive traineeships 

21.  improve  outreach  to  potential  trainees  belonging  to  groups  in  vulnerable  situations, 

including  by  raising  awareness  of  the  benefits  of  quality  traineeships  in  terms  of 

increased employability. 

22.  ensure  equal  treatment  and  non-discrimination  in  traineeships,  including  in  selection 

criteria and recruitment policies, and improve access to traineeship opportunities for all 

potential applicants, in particular those from groups in vulnerable situations. 

23.  ensure  that  traineeship  providers  use  gender  neutral  and  inclusive  language  in  their 

vacancy notices and advertisements. 

24.  ensure that traineeship programmes, including workplaces, trainings, digital tools, office 

and work equipment,  are adapted to  the individual needs  of trainees  where relevant,  in 

particular  for  trainees  with  disabilities,  also  through  the  provision  of  appropriate 

reasonable accommodation in line with Article 5 of Council Directive 2000/78/EC. 

Cross-border traineeships 

25.  facilitate the cross-border mobility of trainees in  the Union  inter alia, by  clarifying the 

national  legal  framework  applicable  to  traineeships  and  establishing  clear  rules  on 

hosting trainees from and the sending of trainees to other Member States and by reducing 

administrative formalities. 

26.  make  use  of  the  EURES  network  to  support  cross-border  mobility  of  trainees  and 

exchange  information  on  paid  traineeships  through  the  EURES  portal,  in  accordance 

with  the  corresponding  provisions  of  Regulation  (EU)  2016/589  of  the  European 

Parliament and of the Council (61). 

27.  further  develop  practical  guidance  material  and  information  for  (potential)  trainees  on 

cross-border  traineeships  through  EURES,  including  in  formats  that  are  accessible  to 

persons with different types of disabilities. 

61 

Regulation  (EU)  2016/589  of  the  European  Parliament  and  of  the  Council  of  13  April  2016  on  a 
European  network  of  employment  services  (EURES),  workers'  access  to  mobility  services  and  the 
further  integration  of  labour  markets,  and  amending  Regulations  (EU)  No  492/2011  and  (EU)  No 
1296/2013 (OJ L 107, 22.4.2016, p. 1.). Available online. 

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28.  support traineeship providers and education and training institutions in facilitating cross-

border  traineeships,  making  the  best  use  of  European  initiatives,  in  particular  the 

Erasmus+  programme  established  by  Regulation  (EU)  2021/817  of  the  European 

Parliament and the Council (62). 

29.  encourage  applying  the  principles  of  this  Recommendation,  where  applicable,  in 

traineeship  mobility  agreements  between  sending  organisations  in  the  European  Union 

and hosting organisations outside the Union. 

Additional traineeship support 

30.  encourage  traineeship  providers  as  well  as  intermediary  organisations,  such  as 

employment services and education and training institutions, to provide career guidance 

support during the traineeship, such as career counselling and networking opportunities, 

to facilitate the transition to a regular employment relationship after the traineeship. 

Framework conditions 
31.  ensure the active involvement of social partners in applying this Recommendation. 

32.  promote  the  active  involvement  of  employment  services,  education  and  training 

institutions,  training  providers  and  other  relevant  stakeholders  in  applying  this 

Recommendation. 

33.  ensure  that  representatives  of  workers  may  engage  in  any  relevant  judicial  or 

administrative  procedure  to  enforce  any  of  the  rights  and  obligations  arising  from 

applicable national law. They may act on behalf or in support of one or several trainees 

in the case of an infringement of any right or obligation arising from applicable national 

law, with that trainee’s or those trainees’ approval. 

Implementation at national level 

Applying the reinforced Quality Framework for Traineeships 

34.  take appropriate measures to apply this Recommendation as soon as possible and submit 

an  implementation  plan  setting  out  the  corresponding  measures  to  be  taken  at  national 

level by [date of adoption + 18 months]. 

62 

Regulation (EU) 2021/817 of the European Parliament and of the Council of 20 May 2021 establishing 
Erasmus+: the Union Programme for education and training, youth and sport and repealing Regulation 
(EU) No 1288/2013 (OJ L 189, 28.5.2021, p. 1). Available online. 

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35.  envisage financial and/or non-financial support such as practical guidance to traineeship 

providers  particularly  for  reaching  out  to  vulnerable  groups  and  for  micro-,  small  and 

medium-sized companies, in applying this Recommendation. 

Support to increase trainees’ employability 

36.  offer  incentives  to  traineeship  providers  for  offering  trainees  a  regular  employment 

relationship after the successful completion of a traineeship. 

37.  make  use  of  the  relevant  Union  funds  and  instruments  for  increasing  the  number  of 

quality traineeships which follow the guidance outlined in this Recommendation. 

Follow-up 

38.  jointly  with  the  Commission,  work  on  the  collection  of  data  on  traineeships,  with  a 

particular view to informing policy making on quality traineeships. 

Done at Brussels, 

For the Council 
The President 

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