As of January 1, 2024, it is compulsory to pay contributions for all trainees who carry out paid and unpaid training placements in companies according to Royal Decree-Law 2/2023 and Royal Decree-Law 5/2023. As a result, with the entry in force of the aforementioned legal texts, companies will not only have to pay contributions for those students who carry out paid internships – which has been the case to date – but will also have to pay contributions for all those students who carry out internships without paying contributions, thus including all interns in the General Social Security Scheme as assimilated (university students on bachelor’s, master’s, doctorate, own degrees and vocational training students, provided they do not carry them out under the intensive vocational training scheme).

In view of the above, the following is a brief analysis of the social security effects of this regulatory change:

  • Coverage for students on internships. Students on paid internships will pay Social Security contributions except for unemployment, FOGASA (Wage Guarantee Fund) and vocational training; however, those on unpaid internships will also be excluded from the temporary incapacity benefit for common contingencies. In both cases, no amount will be provided by the MEI (Intergenerational Equity Mechanism).
  • Social Security costs for companies. A reduction of 95% in contributions for common contingencies has been approved, and no other contribution benefits can be applied. In paid internships, the minimum contribution base will be those corresponding to group 7, i.e. 1,260 euros/month; while in unpaid internships, 2.65 euros will be paid for each day of registration.
  • Daily management and processing of this obligation. A specific Social Security contribution account code must be requested for this group of people. Likewise, there will be a period of 10 calendar days to process the registration and cancellations of unpaid internships in Social Security. In addition, the deadline for payment of Social Security contributions for unpaid internships will be quarterly (contributions for January, February and March will be paid in April and so on).
  • Transitional regime. Students who have carried out unpaid internships prior to the entry into force of the regulation may sign a special agreement with the Social Security for the purpose of paying contributions for the time they have carried out unpaid internships for a maximum period of two years. An exceptional period has also been established until 31 March 2024 to register registrations of unpaid internships that took place between 1 January and 20 March 2024.

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All information contained in this publication is up to date on 2023. This content has been prepared for general guidance on matters of interest only, and does not constitute professional advice. You should not act upon the information contained in this chart without obtaining specific professional advice.No representation or warranty (express or implied) is given as to the accuracy or completeness of the information contained in this content, and, to the extent permitted by law, AUXADI does not accept or assume any liability, responsibility or duty of care for any consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this chart or for any decision based on it.

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