Changes in the pricing of labor practices

• Since January 1, 2024, Royal Decree Law 2/2023 has introduced a series of modifications to the pricing of labor practices

From January 1, 2024, the Royal Decree Law 2/2023, of March 16, on urgent measures to expand the rights of pensioners, reduce the gender gap and establish a new sustainability framework for the public pension system has introduced a series of modifications to the pricing of labor practices.

This implies that all companies are required to register their interns with Social Security, regardless of whether they carry out paid internships or not. It is necessary to register all university and vocational training students who carry out training internships or external academic internships.

Let's look at the changes made by type of practice:

• Paid work internships: The 100 % bonus in the Social Security contribution is eliminated and a single monthly fee is applied for common and professional contingencies that will be updated annually. The person responsible for its application will be the entity that finances the training program. Registrations and cancellations in Social Security will be carried out according to the general applicable regulations.

• Unpaid work practices: The mandatory registration and contribution to Social Security is established for students who carry out these internships. The person responsible for its application will be the company where the practices are developed, which will have the obligation to:

• • Assign a Social Security number to the student (if they do not have one).
  • Communicate to the General Treasury of Social Security the registrations and cancellations that correspond to the beginning and end of the internship.

Quote for work practices

As a general rule, although interns contribute to Social Security, they will do so with a series of particularities:

• They will not contribute for unemployment benefits.
• They will not be quoted by FOGASA.
• They will not pay for vocational training.
• They are not going to contribute the MEI (intergenerational equity mechanism).

In particular:

• Paid work internships: It will be quoted applying the contribution rules for alternation training contracts, established in the state's general budget law. The minimum contribution base will be the minimum in force in each year for group 7.
• Unpaid work placements: it will be quoted by paying a fee for companies for each day of internship, covering common contingencies as professionals:
  • Common contingencies: 2.54 euros per day of registration (0.13 euros subsidized at 95 %), with a maximum of 57.87 euros/month (2.89 euros/month subsidized).
  • Professional contingencies: 0.31 euros per day of registration, with a maximum of 7.03 euros/month.

The deadline to pay these fees would be established as follows:

• Entry of fees for January, February and March will be made in April.
• Entry of fees for April, May and June will be made in June.
• Payment of fees for July, August and September will be made in October.
• Payment of fees for October, November and December will be made in January.

Retroactive nature of the rule 

The Royal Decree Law 5/2023, of June 28, does not establish retroactive effects, but specifies the option of entering into a special agreement paid by the scholarship recipients for a period of 5 years.

People who, prior to January 1, 2024, had provided their services as scholarship holders «pThey will be able to sign a special agreement, for a single time, within the period, terms and conditions determined by the Ministry of Inclusion, Social Security and Migration, which enables them to calculate the contribution for the periods of training or carrying out non-work internships and academic studies carried out before that date of entry into force, up to a maximum of five years».