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Are you considering interns or work experience this summer

Discover the legal and practical considerations for UK employers offering internships or work experience placements in summer 2025


Author: Hannah Thomas

6 minute read

As summer approaches, employers across the UK may be arranging work experience opportunities to local students, college leavers or recent graduates; or may have been approached with requests for these. Where offered, these short placements can provide real value if properly organised.

Why take on interns/work experience placements? 

Work experience can be a crucial pathway into work life and there is a strong business case for offering them where businesses are in a position to do so. Many people, especially recent school leavers, graduates or career switchers, use internships to explore different industries and decide on their career paths or gain key transferable skills for future employment. 

In my own case, I owe my ability to touch type (for which I am still grateful in my day-to-day work life) to a volunteer position I did while I was a post-graduate student. For employers, it's an opportunity to assess individuals for potential future employment. However, businesses must ensure they have the capacity and proper supervision to provide these opportunities. 

What about unpaid work experience or internships?   

In the UK, 'internship' has no legal meaning. Anyone classified as a 'worker' is entitled to at least the National Minimum Wage (NMW) and other statutory entitlements. Apprentices have a lower minimum hourly rate, and government-funded apprenticeship schemes offer structured training in specific sectors.

Article highlights

  • Unpaid internships may breach UK National Minimum Wage laws
  • Employers must ensure insurance, supervision and safety compliance
  • Data protection and confidentiality apply, even for short placements

When you do not need to pay the NMW:

  • The placement is part of a UK-based further or higher education course.

  • The individual is under 16.

  • Voluntary workers for a charity or voluntary organisation, provided they receive no monetary payments except for expenses.

  • They are shadowing or volunteering without work obligations (i.e. they are not a ‘worker’ for the purpose of the NMW legislation)

When you must pay the NMW:       

  • The individual is performing actual work with set hours and tasks.

  • They receive any promise of future work or reward.

Has there been a recent change in the law on interns?

The UK government is proposing an amendment to the Employment Rights Bill, to provide in future that unpaid internships will be prohibited, except when they are part of a recognised education or training course (e.g. mandatory university placements or vocational training).

While there is a strong ethical and moral argument against unpaid internships which inevitably exclude those who are not in a financial position to take them up, in favour of those who are able to do so, they are not necessarily unlawful. Under existing law, most unpaid internships are already technically illegal: if the intern performs tasks consistent with worker status, they must be paid the National Minimum Wage.

The penalties for non-compliance with the NMW legislation are high (up to 200% of the underpayment (capped at £20,000 per worker)). However, despite some high-profile enforcement cases by HMRC over the years, there have been a relatively low number of prosecutions against employers under the National Minimum Wage legislation for unpaid internships; hence the call for the tightening of the law against ‘exploitative’ internships and its enforcement in this area.

Internships can unlock career paths - but legal pitfalls must be avoided

Insurance and Health & Safety       

  • Employer’s Liability Insurance is legally required and typically covers work experience students—but always check your policy.
  •        
  • Public Liability Insurance is strongly recommended.
  •        
  • Health & Safety: Conduct a risk assessment and provide clear safety instructions. Any information about working safely and other safety aspects should be included in a briefing or induction. If the individual is under 18, their needs and inexperience must be specifically considered.         

Data protection

Even on a short placement, you are likely to be processing personal information about the individual and they might be processing your customers’ personal data or even business-sensitive information.       

  • Provide a brief data protection policy and privacy notice.
  •        
  • Ask them to sign a basic confidentiality agreement if they might have access to company confidential information

If you’re hosting someone under 18:       

  • Assign a responsible supervisor.
  •        
  • Avoid hazardous tasks or lone working.
  •        
  • Liaise with their school or college if applicable.
  •    

Useful resources:

  1. GOV.UK: NMW & Work Experience
  2. HSE: Young People and Work Experience
  3. ACAS: Internships and the Law

 

Employers, membership organisations and other businesses who have access to the Markel Business Hub will find guidance on taking on interns and volunteers and the National Minimum Wage; as well as template documents and contracts for employers and other businesses.