Do You Have to Pay Interns in the UK? Intern Pay and the Minimum Wage

Unpaid internships are one of the most misunderstood areas of UK employment law. Some employers assume that calling someone an "intern" or a "volunteer" means they do not have to pay them. It does not, and getting it wrong can mean back pay at today's rates, a penalty of up to twice the underpayment and your business name on a government list.

This guide sets out the legal position in October 2026, the current minimum wage rates, the exemptions that genuinely apply, and what to pay summer interns and placement students in practice. If you are planning a wider graduate hire, start with our guide to how to hire graduates in the UK.

Do you have to pay interns in the UK?

Yes, if they count as a worker, and most interns doing real work do. GOV.UK's guidance on interns says an intern who is a worker is normally due the National Minimum Wage, whatever you call them.

The government's minimum wage guidance on work experience and internships is blunt: "the term 'intern' has no legal status under minimum wage law." What matters is the reality of the arrangement, not the job title or the paperwork.

You cannot contract out of it either. GOV.UK says employers cannot avoid paying the minimum wage by stating that it does not apply, or by making a written agreement saying someone is not a worker or is a volunteer. And if you promise an intern a contract of future work, that alone makes them a worker who is due the minimum wage.

The problem is not rare. The Sutton Trust found that 61% of internships taken by recent graduates were unpaid or underpaid, a figure the government cited when it launched its review of unpaid internships in July 2025.

When does an intern count as a worker?

An intern is a worker if they have an arrangement, written or not, to do work personally for you in return for some reward, and they are not running their own business with you as a client. In practice, if they have set hours, real tasks and someone checking their output, treat them as a worker.

Ask these questions about the internship:

• Are they doing work you need done? Writing content, building a spreadsheet, handling customer emails or researching leads is work.
• Are they expected to turn up? Set hours or days, and consequences for not attending, point to worker status. GOV.UK says a genuine volunteer can decline to turn up and cannot be penalised for not doing the work.
• Do they get anything in return? Money above genuine out-of-pocket expenses is evidence of worker status. So is a promise of a paid job afterwards, which GOV.UK says can count as a benefit in kind.
• Would you replace them if they left? If the work would otherwise fall to an employee, it is almost certainly a job.

If the honest answer to most of these is yes, the intern is a worker. If they are an employee (for example, on a longer paid internship with regular hours), they may also have wider employment rights.

What are the minimum wage rates from 1 April 2026?

From 1 April 2026, the National Living Wage for workers aged 21 and over is £12.71 an hour, and the National Minimum Wage is £10.85 for 18 to 20 year olds and £8.00 for under 18s and apprentices. Interns are paid by age, like any other worker; being a student does not change the rate.

The rates are from GOV.UK's National Minimum Wage rates page. The weekly and 10-week figures are the hourly rate × 37.5 hours, and × 10 weeks, before tax.

The apprentice rate only applies to apprentices under 19, or aged 19 or over in the first year of their apprenticeship. It cannot be used for interns. Rates change every April, so check again before you set pay for summer 2027.

Many employers choose to pay more. The Living Wage Foundation's voluntary real Living Wage is £13.45 an hour across the UK and £14.80 in London for 2025/26, and applies to workers aged 18 and over. New rates are due to be announced on 15 October 2026.

Which interns do not have to be paid?

Only a few groups are outside the minimum wage: students on a required course placement of up to a year, pupils of compulsory school age, people who are purely shadowing, and genuine volunteers or voluntary workers for charities. Each exemption has conditions, and they are easy to stretch too far.

Students on a required placement

Students required to do an internship or placement as part of a UK-based further or higher education course are not entitled to the minimum wage, as long as the placement lasts no more than one year. The government's guidance adds that the exemption does not apply to students doing work unrelated to their course. A summer job that is not a course requirement is not covered, even if the intern is a student.

School work experience

Work experience students of compulsory school age are not entitled to the minimum wage. This covers school work experience placements, not a recent school leaver.

Work shadowing

If the internship only involves shadowing, meaning the person observes and carries out no work, you do not have to pay the minimum wage. As soon as they start producing work for you, it is no longer shadowing.

Volunteers and voluntary workers for charities

Genuine volunteers have no obligation to turn up and get no reward, though they can be paid back reasonable out-of-pocket expenses. Voluntary workers are a separate exemption: they work for a charity, voluntary organisation, associated fundraising body or statutory body, and receive no payment apart from limited benefits such as reasonable travel or lunch expenses. A commercial business cannot use either route for an intern who is doing real work.

University careers services often draw the same line. Imperial's careers service requires adverts to comply with the National Minimum Wage Act 1998 and only advertises unpaid roles for registered charities or genuine work shadowing, and Nottingham's will not advertise vacancies that do not pay the legal minimum wage, apart from volunteering with registered charities.

What should you pay summer interns and placement students?

Pay at least the minimum wage for the intern's age, and ideally a pro rata share of what you would pay a graduate in the same team. Large employers pay well above the floor: Institute of Student Employers members reported typical salaries of £24,159 for interns and £24,000 for placement students in their 2024 survey, expressed as annual rates.

That ISE figure dates from 2024 and comes mostly from large employers with formal programmes. For comparison, a full-time worker aged 21 or over on the April 2026 National Living Wage earns £24,784.50 a year (£12.71 × 37.5 hours × 52 weeks), so the legal floor is now slightly above the typical rates ISE members reported in 2024.

Practical benchmarks for an SME:

The last row is £28,000 ÷ 52 weeks × 10 weeks, which works out at about £14.36 an hour on a 37.5-hour week.

Placement students usually work for 9 to 12 months in the middle of a degree. Even when the placement is a course requirement and exempt from the minimum wage, paying a salary makes your role far more competitive. ISE members, which typically pay placement students the salaries above, received 123 applications per placement hire in 2024/25. An unpaid placement competes with those roles for the same students, and limits your pool to those who can afford to work for free.

Not sure whether you are offering an internship or a placement? Our guide to internship vs work placement explains the difference, and why internships are the smartest way for SMEs to hire graduates makes the business case.

What else do you owe a paid intern?

A paid intern who is a worker gets the same core rights as any other worker: paid holiday, a written statement of terms, and the usual payroll deductions and checks. Budget for these on top of wages.

• Holiday. Workers are entitled to 5.6 weeks' paid holiday a year, building up pro rata. A full-time, 10-week intern builds up about 5.4 days (5.6 weeks × 10 ÷ 52 = 1.077 weeks). Any statutory holiday not taken must be paid when they leave: about £513 for a 21-year-old on the minimum wage (1.077 weeks × £476.63).
• Written statement. Workers must get a principal written statement on their first day, covering pay, hours, holiday and how long the internship will last.
• Employer National Insurance. 15% on earnings above £96 a week in 2026/27, or nothing up to £967 a week for interns under 21 (GOV.UK rates and thresholds). For a 21-year-old on £476.63 a week, that is about £57.09 a week, or £570.94 over 10 weeks.
• Pension. Interns aged 22 or over earning £192 or more a week must be assessed for automatic enrolment, but you can postpone for up to three months if you write to them within six weeks, which covers an internship of three months or less.
• Right to work. Check before they start. The Home Office's employer's guide of 1 October 2026 brings people on worker's contracts into the Right to Work Scheme for work starting on or after that date, alongside employees.

Adding it up for a 21-year-old on the minimum wage for 10 weeks: £4,766.25 in wages, £570.94 in employer National Insurance and about £513 in holiday pay if none is taken, so roughly £5,850 in total. For a full breakdown of employment costs, see how much it costs to hire a graduate.

How is intern pay enforced, and what are the penalties?

HMRC enforces the minimum wage, working with the new Fair Work Agency, and can order you to pay arrears at today's rates plus a penalty of 200% of the underpayment. Employers who owe more than £500 can also be publicly named.

The Fair Work Agency launched on 7 April 2026, and HMRC continues to enforce the minimum wage until the function moves to the agency in April 2027. Interns can raise a complaint through GOV.UK's pay and work rights service, or call the free Acas helpline on 0300 123 1100 for advice.

If an investigation finds underpayment, you receive a Notice of Underpayment. According to HMRC's guidance on the notice:

• Arrears are worked out at current rates, so a 2025 underpayment is repaid at 2026 rates.
• The penalty is 200% of the underpayment for each worker, with a minimum of £100 per notice and a maximum of £20,000 per worker.
• The penalty is halved if all the arrears and the penalty are paid within 14 days, according to the government's enforcement report for 2024 to 2025.
• Naming is possible where total arrears exceed £500.

Enforcement is active. In 2024/25, HMRC identified around £5.8 million in arrears owed to 25,200 workers and issued around 750 penalties totalling £4.2 million, according to that same report. Unpaid internship adverts also draw attention: the government's guidance says adverts that suggest illegal unpaid positions inform HMRC's risk assessment, and employers judged to be at risk may be targeted for investigation.

The government has decided not to ban unpaid internships outright for now. Its response to the call for evidence, published in February 2026, commits to expanding the guidance, cracking down through existing channels and the Fair Work Agency, and running awareness campaigns, while not ruling out legislation if existing protections prove insufficient. It also restates that unpaid internships outside the education exemption are unlawful where the intern is in reality a worker.

How do you set up a fair, legal internship?

Decide the purpose, pay at least the minimum wage, put the terms in writing and give the intern real work with real support. A well-run internship is also one of the best ways to find your next graduate hire.

1. Define the project. One meaningful piece of work they can finish in the time, plus a clear end date.
2. Set the pay. At least the rate for their age; consider the real Living Wage or a pro rata graduate salary.
3. Do the paperwork. Right to work check before day one, written statement on day one, payroll set up.
4. Assign a manager. Someone with time for a short daily check-in in week one and a weekly review after that.
5. Advertise it properly. Include the pay in the advert. You can list it on university careers services and on the GradWorx jobs board with GradWorx Attract, where students browse internships and placements for free.
6. Plan the ending. A final review, a reference, and a conversation about a graduate role if they have done well.

Students reading this: if you have been offered an unpaid role that sounds like a real job, it probably is one in law. Our article on why work experience matters more than your degree explains how to make the most of an internship, and you can find paid ones on GradWorx Search.