As part of the current UK government's Make Work Pay agenda, a call for evidence on unpaid internships was launched in July 2025. In fact, it was not simply internships that were unpaid (or paid less than the National Minimum Wage) that were included - the call for evidence related to work trials, voluntary workers, volunteers and work shadowing.
The call for evidence did not attract a significant response, with only 358 responses. Of those, 117 came from employees, workers or individuals; 82 from academic stakeholders, and 52 from employers and businesses. Only 6 came from trade union or staff associations.
Conclusions from the call for evidence
Currently, unpaid internships are prohibited unless they are part of an educational or training course. The UK government response ("the Response") indicates that this will not change. Stakeholders, including the Chartered Institute of Personnel and Development, indicated that a number of their members believe the existing legislation in this area, if properly understood and enforced, would protect most interns who have worker status. However, there is a lack of awareness around the law and employer responsibilities, leading to confusion for employers and workers.
In response, the UK government has indicated that it will take three key actions:
- Reviewing and expanding existing guidance on the law. This includes the NMW guidance to make it easier for workers to identify when they have been mistreated and the actions they can take to enforce their rights.
- Cracking down on unscrupulous employers via existing enforcement channels and the Fair Work Agency.
- Bolstering existing communication campaigns from within and outside of government to help young people understand their rights and the actions they can take if not properly paid.
The Response to work trials was similar, with a commitment to updating relevant guidance and encouraging individuals to report misuse. NMW guidance on voluntary work is also to be reviewed. While there was a limited response to the call for evidence questions on work shadowing, there was enough to conclude that it is not commonly used. The government stated it did not intend to limit opportunities that allow individuals to "freely contribute to their communities, causes that matter to them, give them opportunities to test a job or a workplace before they make a career change, or take on a new role".
Comment
The Response confirms that the UK government currently has no intention to introduce new legislation in this area. However, it has not been ruled out entirely should the measures set out in the Response not be effective. The response largely relies on improving understanding of the law via guidance - not an easy task when it comes to employment status and the NMW.
