opinion parliamentary committee draft, 7 January 2025
On the proposal for a directive of the European Parliament and of the Council on improving and enforcing working conditions of trainees and combating regular employment relationships disguised as traineeships (‘Traineeships Directive’)
Document CULT-PA-767866 · (COM(2024)0132 – C100004/2024 – 2024/0068(COD))
Committee on Culture and Education · Rapporteur: Nicola Zingaretti
AI:In short
The Committee on Culture and Education's draft opinion amends the proposed Traineeships Directive. It adds a written and paid contract requirement, defines four types of traineeships, and requires equal treatment with comparable regular employees including pay, social protection, health and accident insurance. It sets a six-to-twelve-month time limit for excessive duration, requires vacancy notices to state tasks, working conditions and pay, and asks Member States to improve access for people facing higher obstacles. It adds learning outcomes, mentoring and certification, and requires traineeships to be recognised as valid work experience in recruitment.
Position. The Committee on Culture and Education proposes amendments to the Traineeships Directive, including a written paid contract requirement, definitions of four traineeship types, equal treatment with regular employees, a six-to-twelve-month time limit, and improved access for vulnerable groups.
Key points
- Member States should ensure trainees are covered by a written and paid employment contract of limited duration.
- The Directive would apply to open-market traineeships, active labour market policy traineeships, mandatory professional training traineeships, and traineeships in formal education curricula.
- New definitions cover learning and training components, open-market traineeships, active labour market policy traineeships, mandatory professional training traineeships, and formal education traineeships.
- Trainees must not be treated less favourably than comparable regular employees on working conditions including pay, social protection, health and accident insurance, unless objectively justified.
- Member States must take measures to improve access to traineeships for people in vulnerable situations, including persons with disabilities, rural residents, migrants, Roma, and those with lower educational attainment.
- Member States must define a time limit of six to twelve months indicating excessive duration of a traineeship and of repeated or consecutive traineeships with the same employer.
- Employers must include gender neutral and inclusive information in vacancy notices on expected tasks, responsibilities, work intensity, working conditions including pay, social protection, health and accident insurance, and learning and training components.
- Learning outcomes must be agreed between trainee and employer, indicated in the traineeship agreement, and recognised through a traineeship certificate, Europass or micro-credentials.
- Member States should guarantee that traineeships are recognised as valid work experience in private and public recruitment processes.
- Member States should develop a common quality framework and guidance for employers on the legal framework, labour law, social protection, and quality and accessibility practices.
- Member States should ensure data collection and effective controls and inspections to combat disguised employment relationships.
Who is affected
- Trainees: entitled to written paid contracts, equal treatment, and recognition of learning outcomes.
- Employers: must provide written paid contracts, include detailed vacancy information, and designate mentors.
- Member States: must set time limits, improve access, collect data, and conduct inspections.
- People in vulnerable situations: targeted measures to improve access to traineeships.
Figures and deadlines
Written by AI from the full text · every figure comes from the text · ¶ opens the paragraph · 25 Sept 2026 · Report a problem
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Text 147 paragraphs
AMENDMENTS
The Committee on Culture and Education submits the following to the Committee on Employment and Social Affairs, as the committee responsible:
Amendment 1
Proposal for a directive
Recital 1
| Text proposed by the Commission | Amendment |
|---|---|
| (1) In March 2014, the Council adopted the Recommendation for a Quality Framework on Traineeships (‘2014 Recommendation’) to provide Union-wide quality standards for traineeships. It recommends 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 transitions 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 completion of which is a mandatory requirement to access a specific profession. | (1) In March 2014, the Council adopted the Recommendation for a Quality Framework on Traineeships (‘2014 Recommendation’) to provide Union-wide quality standards for traineeships. It recommends 21 principles for traineeships to improve the quality, accessibility and inclusiveness of traineeships, in particular to ensure high quality learning and training content and adequate working conditions to support education-to-work transitions 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 completion of which is a mandatory requirement to access a specific profession. |
Or. en
Amendment 2
Proposal for a directive
Recital 5
| Text proposed by the Commission | Amendment |
|---|---|
| (5) 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. They can reduce the cost of searching for and recruiting skilled staff, when trainees are offered a regular position after their traineeship. However, this can only be achieved if traineeships are of good quality and offer decent working conditions. | (5) Traineeships have the purpose of helping young people gain practical and professional experience, improving their employability, and facilitating their transition into stable employment. As such, traineeships constitute an important pathway to the labour market. For employers, traineeships provide opportunities to attract and train young people. They can reduce the cost of searching for and recruiting skilled staff, when trainees are offered a regular position after their traineeship. However, this can only be achieved if traineeships are of good quality and offer decent working conditions. |
Or. en
Read the rest (135 paragraphs)
Amendment 3
Proposal for a directive
Recital 8
| Text proposed by the Commission | Amendment |
|---|---|
| (8) Evidence shows that a significant proportion of trainees are subject to less favourable working conditions compared to regular employees, including regarding working hours, leave entitlements, and access to equipment as well as pay. | (8) Evidence shows that a significant proportion of trainees are subject to less favourable working conditions compared to regular employees, including regarding working hours, leave entitlements, and access to equipment as well as pay, exacerbating inequalities among Union citizens from different socio-economic backgrounds. |
Or. en
Amendment 4
Proposal for a directive
Recital 15
| Text proposed by the Commission | Amendment |
|---|---|
| (15) Considering the persisting challenges regarding the problematic use of traineeships in the Union, further action is needed to combat regular employment relationships disguised as traineeships and to ensure that the relevant Union and national law applicable to workers is fully implemented and enforced in relation to trainees. This Directive addresses these challenges by laying down minimum requirements to improve and enforce the working conditions of trainees in the Union and to combat employment relationships disguised as traineeships, by establishing a common framework of principles and measures necessary to ensure equal treatment and to implement and enforce Union and national law applicable to workers more effectively. | (15) Considering the persisting challenges regarding the problematic use of traineeships in the Union, further action is needed to combat regular employment relationships disguised as traineeships, to guarantee high-quality and fair traineeships and to ensure that the relevant Union and national law applicable to workers is fully implemented and enforced in relation to trainees. This Directive addresses these challenges by laying down minimum requirements to improve and enforce the working conditions of trainees in the Union and to combat employment relationships disguised as traineeships, by establishing a common framework of principles and measures necessary to ensure equal treatment and to implement and enforce Union and national law applicable to workers more effectively. |
Or. en
Amendment 5
Proposal for a directive
Recital 15 a (new)
| Text proposed by the Commission | Amendment |
|---|---|
| (15a) Member States should ensure that trainees are covered by a written and paid employment contract of a limited duration, establishing an open-market traineeship, a traineeship in the context of active labour market policies, a traineeship that is a mandatory part of professional training, or a traineeship that is part of curricula of formal education and training. |
Or. en
Amendment 6
Proposal for a directive
Recital 18
| Text proposed by the Commission | Amendment |
|---|---|
| (18) Chapter III of the Directive applies to regular employees who are falsely labelled as trainees, i.e. when employers label a regular employment relationship either as a traineeship which is not an employment relationship, or as a traineeship which does constitute an employment relationship, however with a lower level of pay or other working conditions than those which regular employees would be entitled to under Union or national law, collective agreements or practice. | (18) Chapter III of the Directive applies to regular employees who are falsely labelled as trainees, i.e. when employers label a regular employment relationship either as a traineeship which is not an employment relationship, or as a traineeship which does constitute an employment relationship, however with a lower level of pay, no remuneration or other working conditions than those which regular employees would be entitled to under Union or national law, collective agreements or practice. |
Or. en
Amendment 7
Proposal for a directive
Recital 19
| Text proposed by the Commission | Amendment |
|---|---|
| (19) Traineeships which are employment relationships can be distinguished from ‘regular’ employment relationships in that they are limited in time, they include a significant learning and training component and that they are undertaken in order to gain practical and professional experience with a view to improving employability and facilitating transition to employment or accessing a profession. | (19) Traineeships which are employment relationships can be distinguished from ‘regular’ employment relationships in that, even if paid, they are limited in time, they include a significant learning and training component and that they are undertaken in order to gain practical and professional experience with a view to improving employability and facilitating transition to employment or accessing a profession. ‘Learning and training component’ refers to the learning outcomes that will be acquired by the end of the traineeship, supervision and mentoring arrangements, and a process by which the employer assesses and attests how the learning outcomes were acquired, to ensure their recognition and validation. ‘Learning outcomes’ refer to the knowledge, intellectual and practical skills and competences, such as academic, analytical, communication, decision-making, ICT, innovative and creative, strategic-organisational, and foreign language skills, teamwork, initiative or adaptability, to be acquired by the end of the traineeship. Those learning outcomes should be agreed between the trainee and the employer and indicated in the traineeship agreement. |
Or. en
Amendment 8
Proposal for a directive
Recital 19 a (new)
| Text proposed by the Commission | Amendment |
|---|---|
| (19a) The learning outcomes acquired during the traineeship should be recognised by means of a traineeship certificate, Europass or micro-credentials where relevant, developing a common Union framework. |
Or. en
Amendment 9
Proposal for a directive
Recital 20 a (new)
| Text proposed by the Commission | Amendment |
|---|---|
| (20a) Member States should ensure economic, social and educational measures to improve access to traineeships, particularly to people who face higher obstacles, such as people in vulnerable situations, including persons with disabilities, people living in rural, remote or the outermost regions, people from disadvantaged socio-economic and/or migrant backgrounds, members of the Roma community, and people with a lower educational attainment. |
Or. en
Amendment 10
Proposal for a directive
Recital 22
| Text proposed by the Commission | Amendment |
|---|---|
| (22) Member States should therefore ensure that, in respect of working conditions including pay, trainees are not treated in a less favourable manner than comparable regular employees in the same establishment, unless different treatment is justified on objective grounds. The sole fact of being a trainee cannot constitute grounds for less favourable treatment compared to regular employees in the same establishment. At the same time, different tasks, lower responsibilities or work intensity in relation to comparable regular employees may constitute objective grounds for different treatment, where relevant, with regard to the employment condition at issue. The extent of different treatment should, however, be proportionate to those grounds. | (22) Member States should therefore ensure that, in respect of working conditions including pay, access to social protection, health and accident insurance, trainees are not treated in a less favourable manner than comparable regular employees in the same establishment, unless different treatment is justified on objective grounds. The sole fact of being a trainee cannot constitute grounds for less favourable treatment compared to regular employees in the same establishment. At the same time, different tasks, lower responsibilities or work intensity in relation to comparable regular employees may constitute objective grounds for different treatment, where relevant, with regard to the employment condition at issue. The extent of different treatment should, however, be proportionate to those grounds and a minimum wage for trainees should be established and ensured. |
Or. en
Amendment 11
Proposal for a directive
Recital 24
| Text proposed by the Commission | Amendment |
|---|---|
| (24) Member States should have appropriate measures in place to combat regular employment relationships disguised as traineeships with the effect of granting lower levels of protection, including working conditions and pay, than the worker concerned would be entitled to under Union or national law, collective agreements or practice. | (24) Member States should have appropriate measures in place to combat regular employment relationships disguised as traineeships with the effect of granting lower levels of protection, including learning and training components, working conditions and pay, than the worker concerned would be entitled to under Union or national law, collective agreements or practice. |
Or. en
Amendment 12
Proposal for a directive
Recital 25
| Text proposed by the Commission | Amendment |
|---|---|
| (25) It is necessary to ensure effective controls and inspections conducted by competent authorities as they are essential to protect the rights of trainees and to combat regular employment relationships disguised as traineeships. They should be targeted to avoid the substitution of regular employment by disguised traineeships and to protect workers’ rights. | (25) It is necessary to ensure data collection, effective controls and inspections conducted by competent authorities as they are essential to protect the rights of trainees and to combat regular employment relationships disguised as traineeships. They should be targeted to avoid the substitution of regular employment by disguised traineeships and to protect workers’ rights. |
Or. en
Amendment 13
Proposal for a directive
Recital 27
| Text proposed by the Commission | Amendment |
|---|---|
| (27) Requiring previous work experience for a traineeship in the same or similar field of activity may not indicate a regular employment relationship disguised as a traineeship if the employer provides justification such as an equivalent period of previous work experiences being an alternative to having a degree in a certain field of activity or expertise. | (27) Requiring previous work experience for a traineeship in the same or similar field of activity may not indicate a regular employment relationship disguised as a traineeship if the employer provides justification such as an equivalent period of previous work experiences being an alternative to having a degree in a certain field of activity or expertise. However, in order to ensure that traineeships effectively facilitate the transition to regular employment and prevent repeated or consecutive traineeships with the same or different employers, Member States should guarantee that traineeships are recognised as valid work experience in private and public recruitment processes. |
Or. en
Amendment 14
Proposal for a directive
Recital 29
| Text proposed by the Commission | Amendment |
|---|---|
| (29) Member States should have appropriate measures in place to facilitate the assessment of whether a purported traineeship genuinely constitutes a traineeship. This should include a time limit indicating excessive duration of a traineeship and of repeated, including consecutive, traineeships with the same employer. A reasonable maximum duration of traineeships should, in principle, not exceed six months, as stipulated in the 2014 Recommendation. However, Member States may provide that a longer duration can be justified if it is based on objective grounds. Examples of such exceptions could be traineeships whose completion is a mandatory requirement to access a specific profession, the trajectory of which 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 or vocational education and training may have a longer duration for reasons linked to the curricula. | (29) Member States should have appropriate measures in place to facilitate the assessment of whether a purported traineeship genuinely constitutes a traineeship. This should include a maximum employee to trainee ratio, time limit indicating excessive duration of a traineeship and of repeated, including consecutive, traineeships with the same employer. A reasonable maximum duration of traineeships should, in principle, not exceed six months, as stipulated in the 2014 Recommendation. However, Member States may provide that a longer duration can be justified if it is based on objective grounds. Examples of such exceptions could be traineeships whose completion is a mandatory requirement to access a specific profession, the trajectory of which to acquire the necessary knowledge, competences and experience warrants a longer traineeship experience. Some traineeships that are part of curricula of formal education or vocational education and training may have a longer duration for reasons linked to the curricula. Moreover, in order to facilitate the transition from traineeships to regular employment, Member States should promote incentives for training programmes that offer potential employment with the same employer. |
Or. en
Amendment 15
Proposal for a directive
Recital 30
| Text proposed by the Commission | Amendment |
|---|---|
| (30) The obligation for employers to include information on the expected tasks, working conditions, including pay, social protection, learning and training elements in the vacancy notices and advertisements for traineeships could be fulfilled by including a link to a website containing this information. | (30) The obligation for employers to include gender neutral and inclusive information in the vacancy notices and advertisements for traineeships on the expected tasks and responsibilities, working conditions, including pay, social protection, health and accident insurance, learning and training components could be fulfilled by including a link to an accessible website containing this information. Nevertheless, learning outcomes should be discussed and agreed between the trainee and the employer and the employer should designate a mentor for each trainee. |
Or. en
Amendment 16
Proposal for a directive
Article 1 – paragraph 1 a (new)
| Text proposed by the Commission | Amendment |
|---|---|
| This Directive applies to the following traineeships: | |
| (a) open-market traineeships; | |
| (b) traineeships in the context of active labour market policies; | |
| (c) traineeships that are a mandatory part of professional training; | |
| (d) traineeships that are part of curricula of formal education and training. |
Or. en
Amendment 17
Proposal for a directive
Article 2 – paragraph 1 – point d a (new)
| Text proposed by the Commission | Amendment |
|---|---|
| (da) ‘learning and training component’ means the learning outcomes that will be acquired by the end of the traineeship, agreed between the trainee and the employer and indicated in the traineeship agreement, supervision and mentoring arrangements, and a process by which the employer assesses and attests how the learning outcomes are acquired during the traineeship, to ensure their recognition and validation; |
Or. en
Amendment 18
Proposal for a directive
Article 2 – paragraph 1 – point d b (new)
| Text proposed by the Commission | Amendment |
|---|---|
| (db) “open-market traineeship” means a non-mandatory, bilateral, private agreement between a trainee and a traineeship provider, without the involvement of a third party and without a formal connection to an educational or a training establishment; |
Or. en
Amendment 19
Proposal for a directive
Article 2 – paragraph 1 – point d c (new)
| Text proposed by the Commission | Amendment |
|---|---|
| (dc) “traineeship in the context of active labour market policies” means a traineeship organised by a public employment service in cooperation with a traineeship provider, based on an agreement between the three parties with the aim of helping unemployed or inactive young people into employment; |
Or. en
Amendment 20
Proposal for a directive
Article 2 – paragraph 1 – point d d (new)
| Text proposed by the Commission | Amendment |
|---|---|
| (dd) “traineeship that is a mandatory part of professional training” means a traineeship that is a mandatory introduction into the professional practice of a specific field of work; |
Or. en
Amendment 21
Proposal for a directive
Article 2 – paragraph 1 – point d e (new)
| Text proposed by the Commission | Amendment |
|---|---|
| (de) “traineeship that is part of curricula of formal education and training” means a traineeship that is included in study plans required by an educational institution. |
Or. en
Amendment 22
Proposal for a directive
Article 3 – paragraph 1
| Text proposed by the Commission | Amendment |
|---|---|
| Member States shall ensure that, in respect of working conditions including pay, trainees are not treated in a less favourable manner than comparable regular employees in the same establishment, unless different treatment is justified on objective grounds, such as different tasks, lower responsibilities, work intensity or the weight of the learning and training component. | Member States shall ensure that, in respect of working conditions including pay, social protection, health and accident insurance, trainees are not treated in a less favourable manner than comparable regular employees in the same establishment, unless different treatment is justified on objective grounds, such as different tasks, lower responsibilities, work intensity or the weight of the learning and training component. |
Or. en
Amendment 23
Proposal for a directive
Article 3 – paragraph 1 a (new)
| Text proposed by the Commission | Amendment |
|---|---|
| Member States shall ensure measures to improve access to traineeships, particularly to people in vulnerable situations, including persons with disabilities, people living in rural, remote or the outermost regions, people from disadvantaged socio-economic and/or migrant backgrounds, members of the Roma community and people with a lower educational attainment. |
Or. en
Amendment 24
Proposal for a directive
Article 5 – paragraph 1 – point a
| Text proposed by the Commission | Amendment |
|---|---|
| (a) the absence of a significant learning or training component in the purported traineeship; | (a) the absence of a significant learning and training component in the purported traineeship; |
Or. en
Amendment 25
Proposal for a directive
Article 5 – paragraph 1 – point b
| Text proposed by the Commission | Amendment |
|---|---|
| (b) the excessive duration of the purported traineeship or multiple and/or consecutive purported traineeships with the same employer by the same person; | (b) the excessive duration of the purported traineeship or multiple and/or consecutive purported traineeships with the same or a different employer by the same person; |
Or. en
Amendment 26
Proposal for a directive
Article 5 – paragraph 2 – point c
| Text proposed by the Commission | Amendment |
|---|---|
| (c) the working conditions, including pay, tasks and responsibilities of purported trainees and of regular employees at comparable positions; | (c) the working conditions, including pay, social protection, health and accident insurance, tasks and responsibilities of purported trainees and of regular employees at comparable positions; |
Or. en
Amendment 27
Proposal for a directive
Article 5 – paragraph 3 – subparagraph 1 – point a
| Text proposed by the Commission | Amendment |
|---|---|
| (a) define a time limit indicating excessive duration of a traineeship and of repeated, including consecutive, traineeships with the same employer; | (a) define a time limit of six to twelve months indicating excessive duration of a traineeship and of repeated, including consecutive, traineeships with the same employer; |
Or. en
Amendment 28
Proposal for a directive
Article 5 – paragraph 3 – subparagraph 1 – point b
| Text proposed by the Commission | Amendment |
|---|---|
| (b) require employers to include information on the expected tasks, working conditions, including pay, social protection, learning and training elements in the vacancy notices and advertisements for traineeships. | (b) require employers to include gender neutral and inclusive information in the vacancy notices and advertisements for traineeships on the expected tasks, responsibilities and intensity of work, working conditions, including pay, social protection, health and accident insurance, and the descriptions of the learning and training components. |
Or. en
Amendment 29
Proposal for a directive
Article 6 – paragraph 1 – point b
| Text proposed by the Commission | Amendment |
|---|---|
| (b) develop guidance for employers of trainees regarding the legal framework for traineeships, including relevant labour law and social protection aspects; | (b) develop a common quality framework and guidance for employers of trainees regarding the legal framework, including relevant labour law and social protection aspects, as well as quality and accessibility practices for traineeships; |
Or. en