MAKING WORK PAY

Making Work Pay: Call for evidence on unpaid internships

On 17 July, the Department for Business and Trade launched a call for evidence in relation to unpaid internships, volunteering and other forms of work experience, arising from concern that too many people – often desperate to find work in their chosen industry - are being exploited / expected to work for free.

The call for evidence[RY1]  will run until 9 October 2025, and seeks input in relation to the following key areas:

Unpaid internships and internships which are paid below NMW: the government is concerned that whilst these internships can provide valuable experience, some unpaid interns are performing work that is indistinguishable from that performed by paid workers.

Work shadowing: again, the government recognises that work shadowing can be a valuable learning experience, however, the government wishes to better understand how work shadowing operates in practice, and the potential advantages and disadvantages of these arrangements.

Unpaid work trials: work trials can be used as part of a genuine recruitment exercise to test if a candidate has the skills and qualities required to do a particular role, but the government is concerned that extended unpaid work trials may be being exploited, to avoid having the pay NMW.

Volunteers: volunteers do not qualify for NMW because they are not workers – they typically provide their time and effort completely freely, can come and go as they please, and are under no obligations to provide work/services. The government wishes to better understand how organisations engage and deploy these volunteers.

The government is particularly seeking views from:

• individuals who are, have been, or intend to engage in:

o internships

o work trials

o voluntary work

o volunteering

o work shadowing

• businesses and employers of all sizes

• trade unions and trade union representative organisations

• enforcement agencies

• educational institutions

• non-profit organisations and charities

• employment law experts

• human resources experts and career advisers

• employment or recruitment agencies

If you would like any assistance in collating your experiences or views, please let us know. Equally, if you’re concerned about inadvertent NMW breaches because of unpaid internships or work shadowing schemes, contact us now to arrange a confidential discussion.

 [RY1]call-for-evidence-on-unpaid-internships_making-work-pay.pdf