Alongside the lack of support in finding one, the biting isolation, the bullying and harassment, the placement fee (“that pays for what, exactly”) and the woeful lack of learning, probably the worst was the international student on a physio course who wasn’t warned about the costs of getting to that placement.

Finding another £1,500 is bad enough when you’re already living in a different town to that which the university’s accommodation guarantee promised. It’s worse when you find yourself paying sky high tuition fees and expenses, only to find that the supernumerary status that supposedly underpins your placement is a fictional fantasy.

To then learn that your hardship fund request has been rejected because it features costs “you should have budgeted for” really is insult/injury territory.

That students continue to pay us as a country to prop up the staffing of our own NHS continues to astonish me. Imagine if they all went on strike!

Given the Westminster government’s “Plan for Change” and its determination to “Make work pay”, we might have expected some action over the exploitation involved in internships and placements.

Well, there’s been some. Sort of. Just before recess, the government launched its long-awaited call for evidence on unpaid internships, albeit six months behind schedule.

The headline commitment to uphold, strengthen and enforce the ban on unpaid internships sounds promising – but the consultation document suggests yawning gaps that could undermine the entire policy.

The promise and the reality

The consultation acknowledges a fundamental truth – unpaid internships create barriers to opportunity based on financial circumstances rather than talent.

As the ministerial foreword states:

…access to these opportunities should not be curtailed because of where the individuals live or whether they have the financial support enabling them to work for free.

The principle is sound. Unpaid internships have long been criticised as a form of class gatekeeping, where only those with family financial support can afford to work without pay in prestigious sectors like media, politics, and the arts. The government’s plan to tackle the inequality deserves credit.

It examines unpaid work trials, acknowledging concerns about employers using extended “trial periods” to obtain free labour while claiming recruitment purposes – with government guidance suggesting trials longer than one day should rarely be unpaid.

It covers voluntary workers (those with employment contracts working for charities, voluntary organisations, or statutory bodies who can only receive expense reimbursements) and volunteers (who have no employment contract and can come and go freely).

It also looks at work shadowing arrangements where individuals should only observe rather than perform actual work – and across all these categories, the consultation seeks to understand current practices, compliance with existing National Minimum Wage rules, and whether additional protections are needed.

The government appears genuinely concerned about organisations misclassifying workers to avoid minimum wage obligations and is using the evidence-gathering exercise to understand the scale of non-compliance before strengthening enforcement or introducing new protections.

But the consultation’s scope includes a huge blind spot – because it blithely accepts the status quo of a ban “except when they are part of an educational or training course.”

Part for the course

That exemption already exists in current National Minimum Wage regulations, covering UK and international students at higher or further education institutions who undertake mandatory work experience placements of up to one year as part of their course.

The consultation fails to interrogate what “part of a course” actually means in practice, and nor does it address the grey areas that emerge from this definition.

What constitutes being “part of a course”? I’ve heard endless tales of employers where students claim academic credit for internships that bear little resemblance to meaningful educational experiences. A student might register an unpaid placement with a fashion magazine or political office as an “independent study module” with minimal supervision or learning outcomes. The internship looks educational on paper but functions as free labour in practice.

Even where internships are formally integrated into degree programmes, there’s often a vast difference between the educational theory and workplace reality. Students are promised mentorship, structured learning, and exposure to different departments, only to find themselves making tea, filing papers, or doing basic administrative tasks with little educational value. The consultation doesn’t address how to ensure that “educational” internships actually involve meaningful learning.

Plenty of legitimate work placements are supposed to be “supernumerary” – meaning students are additional to normal staffing levels and not replacing paid workers. In practice, cash-strapped (usually public/health) organisations often use students to fill gaps in the workforce. Hospitals officially say nursing students are there to learn, but unofficially rely on them to maintain safe staffing ratios. The consultation doesn’t explore how to prevent students from becoming essential unpaid labour under the guise of education.

Most ironically, the consultation’s focus on “making work pay” ignores the poverty many students face during those placements. The government seems to assume that because internships are “educational,” the financial hardship they create is somehow justified.

The numbers run like this. The National Living Wage for someone aged 21 and over working 37.5 hours per week comes to £457.88. Meanwhile, the maximum maintenance loan for undergraduates living away from home outside London provides just £351 per week – and that’s money students have to borrow and repay with interest.

We then, of course, signal to international students that they’ll be able to live on that £351 a week.

That creates a ridiculous situation where the government simultaneously argues that work should pay a living wage while expecting students to live on much less than that during placements that in turn prevent them from earning extra money. A student nurse, a teacher in training or even an intern in a law firm or local business can end up working longer hours than many full-time employees but receive no pay beyond inadequate borrowed maintenance funding.

The consultation acknowledges that students face additional costs during placements – travel, accommodation, professional clothing – but offers no solutions. Many are forced to take on debt or part-time jobs alongside unpaid placements, creating exactly the financial barriers to opportunity that the policy claims to address.

In turn, students on educational placements are then routinely excluded from the basic workplace protections afforded to employees or even casual workers. Because they’re not formally classified as workers, they’re not entitled to holiday, or protection against unfair dismissal. They also typically miss out on whistleblowing safeguards, robust health and safety rights, protection from discrimination under employment law, and limited access to enforcement mechanisms — like tribunals or regulators — if they experience mistreatment.

When they get bullied or harassed, who are they complaining to – the university? What is the university supposed to do?

Sector-specific blind spots

The consultation’s broad approach also misses how different sectors exploit the educational exemption in varying ways. In healthcare, social work, and education, lengthy unpaid placements are deeply embedded in professional training. Students in these fields often spend months providing essential services without pay, while their peers in other subjects can access paid internships or focus solely on studies.

That creates a perverse incentive structure where some of society’s most essential workers – future nurses, teachers, and social workers – are expected to subsidise their own training through unpaid labour. The consultation doesn’t examine whether this is fair or sustainable, particularly given the recruitment crises in these sectors.

Even where the consultation does address legitimate concerns, it lacks detail on enforcement. How would authorities distinguish between genuine educational placements and disguised employment? Which authorities? What standards would ensure educational value? How would complaints be investigated?

The document mentions that HMRC enforcement officers consider complaints case-by-case, but provides no confidence that complex educational arrangements would be properly scrutinised. Without enforcement mechanisms, unscrupulous employers easily rebrand unpaid internships as “educational opportunities” to students who’ve been told that they need to find a placement, and continue exploiting free labour.

A half-hearted solution

It’s good news that the government is committed to acting here – unpaid internships perpetuate inequality. The commitment to ban them represents an important step toward a fairer labour market. But the profound lack of curiosity about exploitation under the guise of education renders the consultation almost meaningless.

A genuinely effective approach would need to:

• Define clear standards for what constitutes legitimate educational content in work placements
• Ensure students receive adequate financial support during mandatory unpaid placements
• Establish robust enforcement mechanisms to prevent abuse of educational exemptions
• Address the specific challenges facing students in sectors that rely heavily on placement learning
• Consider whether some “educational” internships should actually be paid positions with structured learning components

In an ideal world, the government’s “make work pay” agenda should apply to all workers, including students. If public services or businesses value the work that students provide during their placements, it’s time to pay them for it rather than expecting them to subsidise their own “training”.

If not, the very least the government could do is ensure that its maintenance loan arrangements are equivalent to the National Minimum Wage, that international students are properly warned about the total costs of study, and that students’ out of pocket expenses (whether home or international) are covered.

The consultation closes on 9 October 2025 – it’s one of those where I’ll be bodging in material to the above effect because the questions don’t otherwise allow it.