The Quality Traineeships Initiative (QTI) is a two-pronged effort by the EU aimed at enhancing the experience and working conditions of trainees across Europe. The initiative stems from a recognition of the growing significance of traineeships in bridging the gap between academic learning and professional careers. The European Commission highlighted that traineeships provide critical skill development and practical experience for youth, helping them integrate into a labour market facing persistent skills shortages. In 2019, an estimated 3.1 million traineeships were conducted in the EU, but considerable gaps were identified regarding fairness and transparency within these programs.

The Commission proposed an EU Directive aimed at significantly improving the working conditions of trainees and addressing the growing challenge of labour and skills shortages across Europe. It enforces several key principles, including the prevention of disguised employment where regular jobs are presented as traineeships. To combat this, Member States will be required to conduct inspections and enforce transparency from employers regarding the learning component and working conditions of traineeships. The Directive also emphasises the principle of non-discrimination, ensuring that trainees receive treatment comparable to regular employees, including fair pay, unless justified by distinct tasks or educational components. Furthermore, it mandates enhanced representation of trainees through workers’ representatives, establishing reporting mechanisms to foster accountability. Lastly, the Directive also focuses on increasing the employability of trainees by encouraging employers to offer tailored career guidance and transition opportunities into regular positions. This ensures that traineeships not only provide immediate learning benefits but also serve as a stepping-stone to long-term labour market opportunities.

The QTI also includes a revision of the 2014 Council Recommendation on a Quality Framework for Traineeships that aims to make traineeships across the EU fairer, more inclusive, and better aligned with the changing labour market. The key elements of the revision include ensuring fair remuneration, access to social protection, enabling hybrid working capabilities, and the appointment of mentors to guide trainees through their work experiences. The recommendation also emphasizes inclusivity, promoting access to traineeships for individuals in vulnerable situations, including those with disabilities.

While the objectives of the QTI are welcome and it is important to enhance the training experience of trainees, it is also essential that the EU legislators consider the practical implications on businesses, particularly SMEs. Two critical concerns need addressing to ensure a successful application: the need to maintain voluntary paid traineeships, and avoid adding administrative burden on SMEs due to excessive reporting obligations.

The QTI should focus on ‘compensation’ which could come in different forms rather than requiring mandatory pay for all traineeships. This distinction is essential as it recognizes the educational and developmental nature of traineeships, which differs from regular employment. Traineeships primarily offer learning opportunities, and many companies, especially SMEs, invest significant resources into providing such programs. A blanket requirement for mandatory pay could discourage businesses from offering traineeships in the first place, particularly considering that trainees’ output is lower than that of regular employees. The primary objective of traineeships should remain educational, and companies should be allowed flexibility in how they compensate trainees, whether through monetary or non-monetary means. Traineeships have been and remain an important entry point to the labour market for young professionals and this approach ensures that they remain accessible while preventing undue burden on companies. ​

A different concern is that SMEs face unique challenges when offering traineeships, as their administrative capacities are often limited. Imposing excessive reporting obligations and frequent inspections on SMEs would be an overwhelming administrative burden. Therefore, investigations and controls should be triggered only when there are specific reports of malpractice or concerns raised by trainees to the competent authorities. Blanket inspections and audits would not only increase the operational burden on SMEs but once more could also deter them from offering traineeships altogether. A more balanced approach would be to empower authorities to investigate traineeships based on specified and verified reports of abuse, rather than subjecting all SMEs to unnecessary scrutiny. This would ensure that SMEs can continue providing valuable traineeship opportunities without facing disproportionate regulatory challenges​.

In conclusion, the QTI represents a significant step toward improving the fairness, inclusivity, and educational value of traineeships across the EU, including Malta. While the initiative addresses key aspects for quality traineeships, it is crucial to balance these goals with the practical realities faced by businesses, particularly SMEs.

Michele Agius is the policy advisor at the Malta Business Bureau (MBB) and can be contacted on magius@mbb.org.mt. 

The MBB is the EU-business advisory organisation of The Malta Chamber and the Malta Hotels and Restaurants Association. It is also a partner of the Enterprise Europe Network.