Alex is Sprintlaw’s co-founder and principal lawyer. Alex previously worked at a top-tier firm as a lawyer specialising in technology and media contracts, and founded a digital agency which he sold in 2015.
- What Counts As An Internship Under UK Law?
- Do You Need An Internship Contract Template In The UK?
- Paid Vs Unpaid Internships: What Are The Rules?
Key Clauses To Include In An Internship Contract Template (UK)
- 1) Purpose, Status And Term
- 2) Pay, Expenses And Holiday
- 3) Working Hours, Breaks And Flexibility
- 4) Supervision, Training And Conduct
- 5) Confidentiality And IP Ownership
- 6) Data Protection And Privacy
- 7) Health And Safety
- 8) Right To Work, Safeguarding And Vetting
- 9) Termination And Early Exit
- 10) Policy Acknowledgements
- Compliance Checklist Before Your Intern Starts
- Common Legal Mistakes With Internship Templates (And How To Avoid Them)
- Key Takeaways
Bringing an intern into your business can be a great way to build a talent pipeline, get fresh ideas on projects, and give someone meaningful experience.
But there’s a catch: under UK law, “intern” isn’t a special legal category. If you get the arrangement wrong, your intern could actually be a “worker” or employee with legal rights to pay, holidays and more.
That’s why it’s smart to start with a clear, legally sound internship contract template tailored for the UK. It sets expectations, reduces risk, and helps you stay compliant from day one.
In this guide, we’ll break down when a UK internship should be paid, what your internship contract should cover, and a practical compliance checklist before you welcome your intern onboard.
What Counts As An Internship Under UK Law?
In UK law, “internship” isn’t a defined status. Your legal obligations depend on what the intern actually does and how the arrangement works in practice.
Broadly, interns tend to fall into one of three buckets:
- Genuine volunteer/student placement: Observational or supervised learning tied to a course, with no set productivity targets, and usually unpaid (but expenses can be reimbursed). These are often short-term and educational in nature.
- Worker: If the intern must personally perform work, follow your direction, and provides value like any other team member, they’re likely a worker. Workers have rights to the National Minimum Wage (NMW), paid holiday, rest breaks and protection against unlawful discrimination.
- Employee: If the arrangement includes mutual obligations (you provide work and they’re obliged to accept it), integration into your team, and ongoing control, they may be an employee with broader rights (e.g. sick pay policies, notice). For these, an Employment Contract is more appropriate than an intern agreement.
It’s the substance of the relationship that counts, not the label. A short “internship” doing real work to commercial deadlines is often a worker relationship at minimum.
If you’re unsure, review the key employment status tests to see where your intern sits, and adjust your contract and practices accordingly.
Do You Need An Internship Contract Template In The UK?
Yes - a proper written agreement is essential. Even for short placements, a clear contract explains the learning goals, confirms any pay/expenses, sets out hours and supervision, and addresses confidentiality and IP ownership. This reduces misunderstandings and ensures you meet your legal duties.
Most small businesses will benefit from a tailored Internship Agreement that aligns with the reality of the role. If the intern is doing productive work and meeting deliverables, the arrangement should be paid and structured like other worker engagements. If it’s strictly educational and observational, your template can reflect that, but you’ll still want clauses on conduct, data protection, and health and safety.
Avoid a one-size-fits-all download. UK rules around pay, hours, equality and health and safety apply regardless of what you call the document. A well-drafted contract that mirrors the actual arrangement is your best protection.
Paid Vs Unpaid Internships: What Are The Rules?
Whether an internship can be unpaid turns on legal status and the nature of the work.
- National Minimum Wage (NMW): If your intern qualifies as a worker or employee, you must pay at least the NMW under the National Minimum Wage Act 1998 and related regulations. This applies even if they’re keen to “volunteer.”
- Genuine volunteering: If they’re truly a volunteer or on a mandatory student work placement as part of a UK-based further or higher education course, the NMW may not apply. You can still reimburse reasonable expenses.
- Expectations and outputs: The more the intern is doing productive work for your business (e.g. delivering tasks to deadlines, covering staff functions), the more likely they’re a worker and must be paid.
The government takes unpaid work seriously. Before you advertise “unpaid internships,” check the unpaid work rules to avoid underpayment risk, reputational harm, or penalties.
Key Clauses To Include In An Internship Contract Template (UK)
Here are the core elements most small businesses will want to cover. Use these as a checklist when designing your internship contract template UK-wide.
1) Purpose, Status And Term
- Purpose: Set out the learning objectives and the nature of the placement (e.g. shadowing, supervised project work).
- Status: State whether the intern is engaged as a volunteer/student placement or as a paid worker. If paid, reflect worker or employee rights appropriately.
- Start/end dates: Include a clear duration and any conditions for extension or early termination.
2) Pay, Expenses And Holiday
- Pay: If they are a worker or employee, confirm hourly rate at or above NMW. Explain how and when they’ll be paid.
- Expenses: For unpaid placements, describe which reasonable expenses (e.g. travel, lunch) you will reimburse and the approval process.
- Holiday: Workers and employees accrue paid holiday; volunteers generally don’t but you should still clarify days off and bank holidays.
3) Working Hours, Breaks And Flexibility
- Hours and rota: Set expected weekly hours and flexibility, including remote or on-site requirements.
- Breaks and rest: Reflect the Working Time Regulations for rest breaks, maximum weekly hours, and night work if relevant.
- Time recording: Explain how hours will be tracked and who supervises the intern.
4) Supervision, Training And Conduct
- Supervisor: Name the person responsible for guidance, feedback and sign-off.
- Training: Outline induction, health and safety briefings, and any mandatory e-learning.
- Standards: Reference your policies (e.g. equality, anti-harassment) and expected professional conduct.
5) Confidentiality And IP Ownership
- Confidential information: Require the intern to keep business information confidential during and after the placement.
- Intellectual property: Confirm that any IP created in the course of the internship belongs to your business, with an assignment clause to transfer rights.
- Work product access: Specify how work should be stored (e.g. on company systems) and returned at the end of the placement.
6) Data Protection And Privacy
- Personal data handling: Set clear instructions for handling customer and employee data, consistent with UK GDPR and the Data Protection Act 2018.
- Policies: Ensure your Privacy Policy and data handling procedures apply to the intern and are acknowledged.
- Systems access: Limit access to what’s necessary and document permissions.
7) Health And Safety
- Duty of care: Confirm your commitment under the Health and Safety at Work etc. Act 1974 and related regulations.
- Risk assessments: State any role-specific hazards and training provided.
- Reporting: Outline how the intern reports incidents or concerns.
8) Right To Work, Safeguarding And Vetting
- Right to work: Include a condition that the intern must have the legal right to work in the UK and provide evidence before starting.
- Safeguarding: If the role involves vulnerable groups, consider whether a DBS check is appropriate and lawful.
9) Termination And Early Exit
- Notice: Provide short, reasonable notice provisions (e.g. one week) for either party to end the placement.
- Immediate termination: Reserve the right to terminate for serious misconduct, confidentiality breaches or loss of right to work.
10) Policy Acknowledgements
- Attach or reference key policies your intern must follow (e.g. equality and diversity, bullying and harassment, IT/acceptable use, data protection, health and safety).
Compliance Checklist Before Your Intern Starts
To help you stay compliant and avoid common pitfalls, run through this practical checklist:
- Decide legal status: Are they a volunteer/student placement, a worker, or an employee? If in doubt, review the employment status tests and structure the arrangement accordingly.
- Pay correctly: If they’re a worker or employee, pay at least NMW and include them in your payroll. Be cautious with “expenses-only” roles - check the unpaid work rules.
- Hours and breaks: Set lawful working hours and breaks in line with the Working Time Regulations.
- Equality and access: Ensure your recruitment and treatment of interns comply with the Equality Act 2010 (no unlawful discrimination; reasonable adjustments where required).
- Right to work: Complete right to work checks before day one. Keep copies per Home Office guidance.
- Health and safety: Provide induction, risk assessments and equipment training. Record completion.
- Data protection: Limit systems access, train on data handling, and ensure your Privacy Policy and related procedures are acknowledged.
- Policies and onboarding: Give the intern access to key policies and assign a supervisor for day-to-day support.
- Agreement in place: Issue and sign the correct Internship Agreement (or, if applicable, an employee-style agreement) before the start date.
If your intern is joining as part of a school or university scheme, double-check any insurance, supervision, safeguarding or reporting obligations that come with that specific programme. For structured programmes, you may also find this work experience placements guide helpful.
How To Build A Practical, Compliant Internship Programme
Beyond the contract itself, a few simple practices will make your internship programme more robust and rewarding - for you and the intern.
Set Clear Learning Objectives
- Agree the skills, tools and exposure the intern will gain.
- Map out a week-by-week plan with achievable tasks.
- Hold regular check-ins to give feedback and adjust the plan.
Structure The Work To Match Legal Status
- For volunteers/student placements, emphasise shadowing, training and observation. Avoid assigning core business output.
- For paid worker-style internships, assign defined deliverables, set realistic deadlines, and pay NMW or above.
Keep Records
- Document onboarding, right to work checks, inductions, and policy acknowledgements.
- Record hours worked and any overtime to ensure compliance with pay and breaks.
Plan For IP And Confidentiality
- Ensure work is done on company systems and stored in shared repositories.
- Collect equipment and revoke access on the final day.
Offer A Fair Exit
- Include a short notice period to end early if it’s not a fit.
- Provide a short reference if appropriate - it reflects well on your brand and helps the intern take their next step.
Common Legal Mistakes With Internship Templates (And How To Avoid Them)
Even with the best intentions, a few pitfalls come up repeatedly for small businesses.
- Relying on generic, non-UK templates: UK-specific laws like the Employment Rights Act 1996, Equality Act 2010 and UK GDPR need to be reflected in your document. Use a UK-tailored Internship Agreement to avoid gaps.
- Calling it “unpaid” while assigning real work: If your intern is working like your staff, they’re likely a worker and must be paid at least NMW. Review the unpaid work rules before posting your ad.
- Ignoring working time limits: Interns are entitled to rest breaks and caps on hours like anyone else. Cross-check your rota with the Working Time Regulations.
- Missing IP assignment: If your intern designs a logo, writes code or produces content, you want those rights assigned to your company within the agreement.
- Skipping privacy onboarding: Anyone with access to personal data needs basic data protection training and to follow your Privacy Policy.
- Using the wrong agreement for an employee-level role: If the intern is effectively integrated as ongoing staff, use a proper Employment Contract and set them up on payroll.
Getting these details right will protect your business and provide a better experience for your intern.
Frequently Asked Questions About UK Internship Contracts
Can An Internship Be Unpaid?
Yes, but only in specific circumstances. If it’s a genuine volunteer or mandatory student placement where the individual is not performing productive work, it may be unpaid (expenses can be reimbursed). If they’re delivering work for your business, they’re likely a “worker” and must be paid at least NMW.
Do Interns Have Holiday Rights?
Workers and employees accrue paid holiday under the Working Time Regulations 1998. Volunteers typically do not, but you should still set expectations around time off in your agreement.
Do We Need To Do Right To Work Checks?
Yes. You must complete right to work checks for anyone performing work or services for your business, paid or unpaid.
What About Young Workers?
If your intern is under 18, additional rules apply on maximum daily hours, night work and breaks. Make sure your plan respects those limits and, where relevant, local safeguarding duties.
Should We Use An Internship Contract Template Or A Full Employee Contract?
It depends on the reality of the role. If the intern is integrated as ongoing staff with mutual obligations, an employee-style agreement is safer. If it’s clearly a time-limited internship with defined learning goals, a UK-specific internship template will usually be appropriate.
Key Takeaways
- “Intern” isn’t a protected status in UK law - if the person is doing productive work, they’re likely a “worker” and must be paid at least the National Minimum Wage.
- Use a UK-tailored Internship Agreement that reflects the real arrangement, including purpose, pay or expenses, hours, supervision, confidentiality, IP assignment, data protection, health and safety, and termination.
- Set lawful hours and breaks, record time, complete right to work checks, and provide proper onboarding and policies (including a Privacy Policy and data handling rules).
- If the role is effectively an employee position, switch to an Employment Contract and set up payroll and holiday accruals.
- Before advertising an “unpaid” role, revisit the unpaid work rules and apply the employment status tests - labels don’t override legal rights.
- For school or university programmes, align with the provider’s requirements and consider this quick guide to work experience placements to round out your compliance.
If you’d like help drafting a compliant internship contract template for your business, or you’re unsure whether your intern should be paid, we’re here to help. You can reach us at 08081347754 or team@sprintlaw.co.uk for a free, no-obligations chat.


