* : Workers’ assessment of the Traineeship Directive Compromise

Brussels, 27 February 2025

To: Social Attaches

Dear Members of the Social Questions Working Party,

We are writing to share our comments on the latest compromise proposal for the Traineeship Directive that will be discussed tomorrow. 

While we recognise and thank the Polish Presidency for the ambition to address the well-documented issue of false traineeships—abusive practices that misuse traineeships for purposes other than facilitating the transition from education to stable employment—we believe crucial elements are still missing in the current compromise.

Limiting the scope to one informally defined category – Open Labour Market Traineeships - risks creating confusion and imposing additional burdens at the national level. Such an approach could also lead to discrimination among trainees: for instance, two individuals applying for the same position through a job portal could face vastly different conditions, with one guaranteed fair working conditions and the other left unprotected if their traineeship is linked to education. 
This kind of discrimination must be avoided, not institutionalised.

Furthermore, we argue that the list of guiding criteria to detect false traineeships should include key factors such as the requirement of previous working experience and the lack of pay. These indicators are essential to effectively identify and address abusive practices.

In the attached document, we provide concrete arguments and proposals to improve the text. 

We hope you will consider these points during your discussions tomorrow and encourage you to contact us for an exchange of views on the dossier before finalising your position on this proposal.

We remain at your disposal for any further clarification or discussion.

Kind regards, 

Tea Jarc 
Confederal Secretary