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Traineeship Directive – HOTREC urges pragmatism in trilogue negotiations

Tuesday, 14 October 2025
Position paper Social Affairs

As the European Parliament and Council enter trilogue negotiations on the proposed Traineeship Directive, HOTREC has published its official position, calling for a balanced approach that safeguards quality traineeships while respecting national competences and the reality of SMEs.

HOTREC recognises the importance of improving conditions for trainees but maintains that a Recommendation would have been a more suitable legal instrument than a Directive, given the diversity of national systems. While supporting the Council’s general approach, HOTREC outlines three key priorities for the final negotiations:

1. Scope
The Directive should apply only to trainees under an employment contract. Traineeships that form part of education, training curricula, or labour market policies must remain outside its scope. Apprenticeships should also be explicitly excluded.
This distinction avoids legal uncertainty and ensures that education systems remain under national competence.

2. Equal Treatment with Proportionate Flexibility
Differentiated treatment between trainees and regular employees should be allowed where justified by different tasks, lower responsibilities or the predominance of a learning component.
Compensation frameworks must reflect the fundamental learning purpose of traineeships.

3. Role of Social Partners
Collective agreements must retain the ability to derogate from certain provisions, in full respect of national labour traditions and subsidiarity.

HOTREC also stresses the need to avoid excessive administrative burdens, particularly for SMEs, which are key providers of traineeships and first-entry opportunities for young people in hospitality.

HOTREC calls on EU co-legislators to deliver a Directive that strengthens youth employment without reducing training opportunities or overwhelming businesses with red tape.

 

Read our full position ahead of trilogue negotiations