Call for evidence on unpaid internships, volunteering, work trials and work experience

The Department for Business and Trade has recently launched a call for evidence in relation to unpaid internships, volunteering and other forms of work experience, with a particular focus on the interaction with the National Minimum Wage (NMW) rules. This will run until 9 October 2025.

In summary, the call for evidence specifically seeks evidence from employers and other stakeholders in relation to the following areas:

• Unpaid internships/paid below NMW: although the government recognises that internships can allow young people to gain the skills and experience needed to succeed in their careers, it is worried that some unpaid interns are performing work that is indistinguishable from that performed by paid workers and internships are being misclassified by some employers to avoid paying interns NMW.
• Unpaid work trials: the government recognises that these can be used as part of a genuine recruitment exercise to test if a candidate has the skills and qualities required for the job, but is concerned that extended unpaid work trials in real, as opposed to simulated, work environments may be being exploited to avoid payment of NMW.
• Voluntary workers: this has a specific meaning for minimum wage purposes and these individuals do not qualify for NMW because they work on a voluntary basis for a charity, voluntary organisation, associated fundraising body, a specified statutory body (e.g....

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