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Affiliation. Registration and deregistration

How are the internships included in the Special Social Security Scheme for Sea Workers identified?

They shall be identified using the same values as for the General Social Security Scheme. The only special features consist of having a specific CCC for the Special Scheme for Sea Workers and the obligation to record the vessel's details (ID or NIB).

How are paid internships started before 1/01/2024 and continuing after that date identified?

They must be identified with RLCE 9939. In order to make this change of identification, a deregistration with an actual date of 31/12/2023 and a registration with an actual date of 01/01/2024 must be made.

Internships included in training programmes linked to university studies for those who have not yet obtained a degree, as well as training placements linked to vocational training studies or certificates of professionalism, started prior to 1 January 2024, which until now have been identified with RLCE 9922 or 9923, shall be identified, with effect from 01-01-2024, with RLCE 9939.

Extracurricular university academic internships, which until now have been identified with RLCE 9927; and curricular internships of university and vocational training students, which until now have been identified with RLCE 9928; started before 1 January 2024, shall continue to be identified, from that date onwards, with the same values and shall maintain their registration in contribution account codes with TRL 986.

External academic internships carried out by university graduates, started before 1 January 2024, to which the legal scheme provided for in Royal Decree 1493/2011 continues to apply, will continue to be identified with RLCE 9923. In cases where such practices could have been identified up to this point with CER 9922, they should be identified with the value 9923.

Can a training centre with direct RED authorisation manage unpaid internships?

No. They must request an SLD authorisation for the management of these Contribution Account Codes since the specific Contribution Account Codes for non-remunerated internships cannot be assigned to RED Directo authorisations because quarterly settlements are not covered by this type of authorisation.

What is the deadline for companies, institutions, entities or training centres to report the days of unpaid internships?

This notification must be made up to the penultimate calendar day of the corresponding regulatory payment period of social security contributions and under no circumstances after the application for calculation of the corresponding settlement of contributions.

29 April, 30 July, 30 October and 30 January, depending on the quarter in which the internship takes place.


Is the company, institution, entity or training centre required to report the number of actual days of unpaid internships performed in a month?

Yes, the company, institution, entity or training centre must provide the following information:

  1. The number of effective days completed on the internship.
  2. If the person performing the internship is in a situation of temporary disability due to professional contingencies, birth and care of a child, risk during pregnancy or breastfeeding, the company must inform the Social Security General Treasury, of the days foreseen for the internship.
  3. That in a given month, no internship has been carried out, remaining registered.

In the case of an internship on board a vessel, under which scheme must the intern be registered?

When the internship or training is carried out on board vessels, the student must be registered in the Special Social Security Scheme for Sea Workers.

How can it be established whether one or more interns do not fall within the scope of Additional Provision 52 LGSS for the purpose of not registering them?

The company or entity that assumes the Social Security obligations must communicate all registrations of interns on internships. At the time of billing and settling the contributions, the Social Security General Treasury will check the days on which each student should have been registered, if applicable, so that the corresponding contributions can be made.

Should the company, entity or training centre responsible for compliance with Social Security obligations request the assignment of a specific Contribution Account Code for students on internships?

Yes, the company, institution, entity or training centre that is responsible shall ask the TGSS to assign a specific contribution account code for each of its training centres for the group of persons on paid internships and another specific contribution account code for the group of persons doing unpaid internships.

What is the deadline for the company, institution, university or training centre to process registrations and deregistrations?

In the case of paid internships, there are no exceptions to the general rule with respect to the General Scheme and the registration must be processed beforehand.

In the case of unpaid internships, the regulatory deadline for communicating registrations and deregistrations is 10 calendar days from the start or end of the internship, respectively.

For registrations and deregistrations that take place between 1 January and 20 March 2024, an exceptional deadline of 31 March 2024 has been set.


Who is required to complete the registration, deregistration and contribution obligations for interns?

The entity considered the employer for the purposes of social security obligations acquires the status of compulsory subject and is responsible for the payment of all contributions:

  • In the case of paid internships, the social security obligations shall be met by the entity or body financing the training programme, which for this purpose shall assume the status of employer. If the programme is co-financed by two or more entities or bodies, the employer shall be the one to which the corresponding financial consideration is paid.

  • In the case of unpaid internships, compliance with Social Security obligations shall be the responsibility of the company, institution or entity at which they are carried out, unless the cooperation agreement or agreement that, where applicable, is signed for their implementation stipulates that they shall be the responsibility of the training centre responsible for the corresponding qualification.


What happens if, at the time of the application for registration, the student is in one of the other excluded or incompatible situations...

What happens if, at the time of applying for registration, the student is in one of the other excluded or incompatible situations (registration or situation assimilated to inscription with obligation to pay contributions or in periods considered as having paid contributions)?

The TGSS will accept the registration with the Social Security for the internship and the registration will be maintained until the communication of the sick leave as a consequence of the end of the training internship. In such cases, the incompatible situation will be taken into account in the corresponding monthly or quarterly instalments.

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