United Kingdom: Government publishes call for evidence on unpaid internships and volunteers

24 Jul 2025    1 minute read

In brief

The government has published the latest in a series of calls for evidence as part of its Making Work Pay manifesto commitment. In the light of a commitment to ban unpaid internships unless part of an educational or training course, the call for evidence asks for information on the current circumstances in which interns are not paid, or are paid below the national minimum wage, and the reasons for this.  

Contents

Key takeaways

  • This call for evidence will be of interest to any organisation that offers unpaid working opportunities (such as unpaid internships or volunteer work), or working opportunities that pay less than the national minimum wage (NMW).
  • Individuals who meet the legal definition of worker are entitled to the NMW (the rate of which is currently modified according to age brackets). There are only limited exceptions to this, e.g., for some educational work placements or voluntary work in a registered charity (as well as in a limited number of other types of organisations).
  • There is no legal definition of an intern or internship. Many such arrangements, when closely scrutinised, might give rise to worker status, and therefore an entitlement to the NMW. 
  • The government also wants to examine how unpaid work trials, work shadowing and volunteering arrangements operate in practice to make sure that those who are entitled to NMW receive it.
  • The call for evidence sets out a long list of questions covering, for example, whether terms such as intern should be defined in law; the numbers of internships or work shadowing opportunities an organisation offers; whether such opportunities should be time limited; and current pay arrangements. 
  • The call for evidence closes on 9 October 2025. The government expects to publish its response in January or February 2026.
  • For more information or to discuss the implications for your organisation, please get in touch with the authors or your usual Baker McKenzie contact.
Contact Information
Julia M. Wilson
Partner
London
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julia.wilson@bakermckenzie.com
Stephen C.M. Ratcliffe
Partner
London
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stephen.ratcliffe@bakermckenzie.com
Rachel Farr
Senior Knowledge Lawyer
London
rachel.farr@bakermckenzie.com

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