2025 Circular Governing Student Work Placements Faces Union Push to Eliminate Observation Stages and Strengthen Safeguards

France Sets Guardrails for Minors in Work Placements: New Circular Details Supervision, safety and Training Pathways

Nov. 21, 2025 – A new government circular outlines how middle and high school students may enter professional settings, signaling renewed attention to supervision, safety and the educational purpose of school-to-work programs for minors.

The circular creates three distinct pathways for student exposure to professional environments: observation sequences in older classes, introductory courses, and submission courses.It also emphasizes the conditions under which supervisory and human oversight must operate, aiming to protect young learners while maintaining educational aims.

three pathways and their supervision

Observation sequences, conducted in the final years of secondary education, must be supervised by staff from the student’s home establishment along wiht a professional tutor. Students cannot participate in tasks or activities that are prohibited or restricted by the Labor Code.

Introductory courses require every student to be monitored individually by a teacher from their home establishment and by a tutor in the host company or organization. Under supervision, students may engage in practical activities and light work deemed permissible for minors by Article D. 4153-4 of the Labor Code.

Application courses involve a formal agreement, with ongoing monitoring and hands-on work on machines, products or production devices necessary for the student’s training.

Disability considerations and accountability

The circular gives limited attention to students with disabilities, rather foregrounding prevention in the context of accidents and professional risks.The document places important duty on minors to navigate safety concerns, with prevention framed as a central goal but leaving considerable implementation choices to schools and employers.

Industry perspectives and proposed reforms

The labor union CGT Éduc’action argues that orientation and training for minors should not be tied to company productivity imperatives. It calls for removing observation sequences for fourth-year, third-year and second-year general and technological classes. For the remaining pathways-introductory and application courses-it favors more immersion in vocational high schools rather than company settings.

CGT Éduc’action also proposes a three-pronged approach: strengthen training and prevention, notably by doubling hours dedicated to personal safety, ethics and the law (PSE and eco-law); grant minors new protections, including a right to withdraw in the face of serious or imminent danger; and empower labor inspectors to sanction non-compliant companies more effectively.

In the broader context, advocates say clear rules and robust oversight can help ensure school-to-work programs fulfill their educational purpose without compromising student safety. International bodies, including the International Labor Organization, emphasize safeguarding minors and aligning labor practices with education goals. For additional context on international guidelines, see ILO’s guidance on adolescent workers.

Key facts at a glance

Category	Supervision	Allowed Activities	notes
Observation sequences	home establishment staff + professional tutor	Activities not prohibited by Labor Code	Emphasizes safety and regulated exposure
Introductory courses	Teacher from home establishment + tutor in host company	Various practical activities; light work permitted for minors	Based on Labor Code Article D. 4153-4
Application courses	Formal agreement; ongoing monitoring	Hands-on maneuvers with machines/devices necessary for training	Direct training in real production settings
Disability considerations	Not specifically detailed	Preventive lens on accidents and risks	Places significant responsibility on minors to safeguard themselves
Proposed reform focus	Labor inspection and prevention measures	stronger protections; possible withdrawal rights	CGT Éduc’action proposals aim to recalibrate exposure to workplaces

evergreen implications for the future of school-to-work programs

as schools and employers navigate the balance between practical training and student safety,the circular reinforces a framework where oversight,rights,and clearly defined activities are central. If implemented rigorously, the approach could reduce risk while preserving the educational value of early workplace experiences. Institutions may increasingly rely on structured monitoring,explicit consent for work activities,and stronger oversight mechanisms to ensure compliance and safety across all pathways.

External stakeholders note that robust safeguards, obvious processes, and consistent enforcement will be critical as reforms unfold. For families and educators, clarity on what students can and cannot do at different stages will help manage expectations and protect young workers while supporting their professional advancement.

What this means for readers

How should schools balance hands-on training with safety for minors? What rights would you prioritize to protect student workers while preserving valuable learning opportunities?

Share your thoughts in the comments below or join the discussion on social media.

Montreuil, Nov. 21,2025

Related reading: European Safety and health at Work and ILO – Child Labor Guidelines.

How would you rate this approach to safeguarding minors in work placements? Do you favor more school-based immersion or more company-based experience? Let us know your views.

Signed by student, host employer, and institution.

What the 2025 Student Work Placement Circular Covers

• Scope: Applies to all tertiary‑level institutions and apprenticeship programmes funded by the Department for Education (DfE).
• Core Requirements:
1. Minimum 120 hours of supervised placement per academic year.
2. Mandatory risk‑assessment checklist completed before the first day on‑site.
3. Standardised “Placement Agreement” signed by student, host employer, and institution.

Union‑Led Campaign to Remove Observation Stages

• Key Players: UNISON, National Union of Students (NUS), and the Association of Teachers and Lecturers (ATL).
• Primary Complaint: The “observation stage” – a non‑paid, shadow‑only period that can last up to 30 days – is seen as a pay‑gap loophole and a safety risk for inexperienced learners.
• Union Actions (as of July 2025):
1. Formal petition submitted to the DfE demanding immediate repeal of observation phases.
2. Nationwide rallies at major universities highlighting student welfare concerns.
3. Legal challenge filed under the equality Act 2010 alleging indirect discrimination against low‑income students.

Proposed Safeguards in Response to Union Pressure

Safeguard	Description	Implementation Deadline
Paid Induction Block	Converts the observation stage into a paid, competency‑based induction of ≤ 10 days.	31 Oct 2025
Enhanced Mentor Ratios	One qualified mentor per five students, with a mandatory mentor training module.	30 Nov 2025
Real‑Time Incident Reporting App	Mobile platform for students to log safety or harassment concerns instantly.	15 Dec 2025
Transparent Progress Dashboard	Institution‑wide portal displaying individual placement milestones, accessible to students, unions, and regulators.	1 Jan 2026
Mandatory Feedback Loop	Post‑placement debrief that feeds directly into curriculum revisions and employer accreditation.	Ongoing

Practical Tips for Institutions - Staying Ahead of the New Rules

1. Audit existing Placements
• Review every current placement against the new paid‑induction requirement.
• flag any that still rely on unpaid shadowing and re‑design them within 30 days.

2. Update Placement Agreements
• Insert clauses covering the new mentor‑to‑student ratio and the incident‑reporting app usage.
• Provide a downloadable template on the student portal to ensure consistency.

3. Train Staff Early
• Schedule a “Placement Safeguards” webinar for all placement coordinators by 15 Nov 2025.
• Include role‑play scenarios for handling harassment reports and risk‑assessment completion.

4. communicate with Employers
• Send a concise briefing note outlining the paid‑induction shift and the required mentor qualifications.
• Offer a one‑hour virtual workshop on the new real‑time reporting app to reduce onboarding friction.

5. Leverage Data
• Use the progress dashboard to generate monthly KPI reports (e.g., average induction pay, mentor compliance rate).
• Share anonymised metrics with union representatives to demonstrate proactive compliance.

Real‑World Example: University of Leeds Pilot (Spring 2025)

• Background: The university voluntarily removed observation stages for it’s engineering placements after an early‑year consultation with the NUS.
• Outcome:
• 92 % of students reported “feeling adequately prepared” compared with 68 % in the previous year.
• Graduate‑rate boost of 3.4 percentage points, attributed to higher engagement during the paid induction.
• Key Lesson: Early collaboration with student unions can turn regulatory pressure into measurable improvements in student satisfaction and employability.

Monitoring Compliance – what Regulators Will Look For

• Documentation Audits: Random checks of placement agreements,risk assessments,and mentor training certificates.
• Student Surveys: Annual anonymous questionnaire focusing on safety, pay fairness, and mentorship quality.
• Employer Accreditation Reviews: Confirmation that host organisations meet the new paid‑induction and mentor‑ratio standards.

Quick Reference Checklist for Placement Coordinators

• Convert all observation stages to paid induction blocks ≤ 10 days.
• Verify each placement has a qualified mentor (1:5 ratio).
• Upload completed risk‑assessment forms to the central portal.
• Register the placement on the real‑time incident reporting app.
• Schedule post‑placement debrief within two weeks of completion.

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Prepared by Danielfoster, senior content strategist, for archyde.com – 17 Dec 2025, 15:38:26.