Grievances Caused by Internship Periods in Retirement

Grievances Caused by Internship Periods in Retirement. Legal Background, 2025 Political Forecasts, and Analysis of 2026 Legal Solution Scenarios

1. Legal and Social Analysis of the Current Situation: The Anatomy of Victimization

The issue of those blocked by internships in retirement is caused by a structural inequality. This long-standing problem exists within Turkey’s social security system. Furthermore, this victimization stems from the narrow scope of insurance premiums. These premiums are paid during internship and apprenticeship periods. The reasons for the aforementioned legal distinction are examined in this report. Next, the effects of Supreme Court jurisprudence are evaluated. Finally, the inequalities with similar groups are presented clearly.

1.A. Definition of Internship and Apprenticeship Insurance within the Scope of Short and Long-Term Insurance Branches

Grievances Caused by Internship Periods in Retirement. Current social security legislation governs the insurance of interns and apprentices. This is regulated specifically within Law No. 5510 on Social Insurance. The Vocational Education Law No. 3308 also frames these regulations. According to these rules, the insurance provided by the working institution covers intern students. However, only short-term insurance branches are covered. These branches include occupational accidents and diseases.

Grievances Caused by Internship Periods in Retirement. A fundamental problem is created by this legal status. This difficulty arises when determining the insurance starting date (ISD). Long-term insurance branches cover invalidity, old age, and death (IOD) insurances. Premiums for these IOD insurances are not deposited. Consequently, the internship or apprenticeship period is not accepted as the official ISD. This applies even if the period was a de facto working period. The process of meeting the required service period and age for retirement begins later. It starts when long-term premiums are first paid. Therefore, this situation causes individuals to lose critical years. This affects those with a pre-1999 insurance start date. It also impacts those wanting to benefit from the EYT regulation. Thus, the victimization termed “being blocked by the internship” has arisen.

1.B. The Effect of Supreme Court Jurisprudence in Determining Scope

High court decisions in social security cases present a complex picture. This relates to when internship periods may be accepted as part of the insurance period. Case law precedents, such as the 2007/22085 E. decision of the Supreme Court, have clarified these periods. They sought to clarify the insurance periods of students working under a vocational training contract.

These decisions have distinguished between days of learning at school and days of actual work at the workplace. The Supreme Court stated that a plaintiff could not be insured during a period of 2 days of school and 3 days of internship per week. However, the plaintiff could be counted as insured during periods when the school was closed. This includes, for example, the summer holidays. These precedents confirm that vocational training time can be assessed as actual work under certain conditions. Nevertheless, they constitute an administrative obstacle. This barrier prevents the collective debt accrual of the entire internship period. Without new legal regulation, the SSI would be forced to examine each intern’s training calendar. This would lead to great practical difficulties in implementation.

1.C. Legal Inequality with Attorney Internships, Military Service, and Other Exceptional Debt Accrual Rights

Grievances Caused by Internship Periods in Retirement. One of the strongest legal arguments of internship victims is this: similar pre-insurance periods have the right to retroactively advance the ISD through debt accrual. The current Law No. 5510 permits debt accrual for certain periods. These include time served under arms as a private or non-commissioned officer. Furthermore, debt accrual is allowed for doctoral or medical specialization periods without insurance. It is also permitted for normal internship periods of those performing attorney internships without insurance.

This situation creates a legal arbitrariness perception for vocational high school students and university interns. An analytical assessment indicates that no acceptable justification for this distinction is found. Even non-traditional periods, like attorney internship or military service, are included in the long-term insurance period. They are included via debt accrual. Conversely, apprenticeship or vocational high school internship periods are excluded. This condition is required by the Vocational Education Law. Therefore, this exclusion conflicts with the principle of equality. Legal regulations grant the right to retroactively advance their insurance start date to individuals performing attorney internships. This is done by accruing debt for this period. This proves that vocational internships hold undeniable potential for retirement rights. Consequently, future legal regulations must resolve this legal inequality. This should be achieved by including vocational internship and apprenticeship periods within the scope of debt accrual.

The dimensions of this legal inequality are shown more clearly below. Long-term insurance rights and debt accrual conditions are compared in the table.

Right Holder Group	Is Insurance Start Date Counted?	Long-Term Coverage Debt Accrual Right	Legal Basis
Private/Non-commissioned Officer Military Service Period	Yes (Goes back with debt accrual)	Yes	Law No. 5510 Art. 41
Attorney Internship Period	Yes (Goes back with debt accrual)	Yes	Law No. 5510 Art. 41
Intern/Apprentice Insured (Current)	No (Only Short-Term)	No	Law No. 5510 / 3308
Intern/Apprentice (Proposed Model)	Yes (Goes back with debt accrual)	Proposed	Draft Laws

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2. Scope of Victimization and the 2025 Political Ground

The solution to the victimization stems from growing social and political pressure. It is not just from legal necessity. As 2025 is entered, the issue is expected to remain permanently on the Parliament’s agenda.

2.A. Profile and Demands of the Victim Population

Grievances Caused by Internship Periods in Retirement. The target audience for internship victimization consists mainly of individuals. These individuals have an internship or apprenticeship insurance start before September 8, 1999. This date is the milestone for fundamental changes in retirement legislation. Thus, the loss of retirement rights for this group constitutes the most critical point. The core groups aimed to be included are vocational high school and university students. Apprenticeship training individuals are also included.

Grievances Caused by Internship Periods in Retirement. Victims are conducting strong organization and lobbying activities. This is managed through the Federation of Internship and Apprenticeship Insurance Victims and various associations. These structures constantly keep their demands on the political agenda. The basic, non-negotiable demands of the associations and federations are clear. The internship and apprenticeship periods must be accepted as the insurance starting point. Furthermore, this period must be included in the long-term insurance branches. Thus, the “Full Insurance Right” must be granted to them. The ultimate goals are the resolution of insurance problems and the recognition of retirement rights.

2.B. Current Draft Laws and Government Strategies for 2025

The demands of internship victims have been brought to the Parliament’s agenda for a long time. For example, a bill previously presented by Deputy Bülent Öz aimed to introduce a debt accrual option for apprenticeship and internship periods. It also aimed to count the period accrued as the retroactive insurance start date. The common denominator of these proposals is providing retroactive application of long-term insurance coverage. This is done with the condition of debt accrual.

The political ground for 2025 is evaluated. The high cost burden on the Treasury from the previously implemented EYT regulation is considered. This requires the government to adopt a cautious approach against a new early retirement regulation. This financial balance necessity will narrow the scope of the decisions to be taken. In this context, the government’s likely response in 2025 will be a limited solution. It will be based on two fundamental restrictions. First, the legal regulation is expected to target only the oldest and loudest cohort of victims. This group has an insurance start date before 1999. Second, the solution is foreseen to be tied to a debt accrual condition. This is a strategy to transfer the cost from the public budget to the individual. This means that the state undertakes only the task of opening the legal path. It avoids directly assuming the cost of retirement.

This limited solution model provides a basis for political compromise. The demand of the most victimized group is met. Yet, the financial sustainability of the social security system is protected. However, this approach postpones the victimization of other groups. These are those who interned or had apprenticeship insurance after 1999. This carries the potential to create a new source of political pressure.

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3. Cost and Financial Modeling: 2025 Financial Projections and SSI Burden Analysis

The inclusion of internship and apprenticeship periods in long-term insurance via debt accrual has a dual financial effect. It creates both instant income and a long-term burden on the SSI budget.

3.A. Intern Debt Accrual Potential and Premium Calculation Methodology

In case the right to debt accrual comes into force, the premium calculation will be made according to existing SSI laws. Accordingly, the premium cost of the accrued period is found by multiplication. It is determined by multiplying the gross minimum wage (MW) at the application date by a determined premium coefficient. This rate generally corresponds to a 32% slice, covering employer and employee shares.

A basis can be created for intern wages and associated debt accrual projections using 2024 data. For example, apprentice and candidate apprentice wages were calculated at 30% of the net minimum wage in 2024. Journeymen and 12th-grade vocational training students were paid at 50% of the net minimum wage. The subsequent raise in the minimum wage in 2025 will directly affect the amount of debt accrual paid by individuals. Since the debt accrual cost is high, it is critically important that this payment does not exceed the individual’s financial power.

3.B. Reflection of Early Retirement Cost on the SSI Budget

The effect of debt accrual on the SSI budget differs in the short and long term.

Positive Short-Term Cash Flow: The premiums paid by victims using the debt accrual right provide a one-time revenue stream to the SSI. This can provide temporary budget support in the first year. This is particularly true when a large group utilizes the debt accrual right collectively.

Negative Long-Term Burden: The main and much larger financial burden results from the early retirement of rights holders. They retire 1 to 4 years earlier due to the retroactive ISD. This causes the SSI to start retirement pension payments much earlier. The debt accrual premiums paid initially often remain insignificant next to this early retirement burden. This is because retirement pensions are a lifelong commitment.

During the internship period, employers have the right to exclude interns from the employee count under Law No. 3308. These employers are only obliged to pay short-term premiums for these students. This means that long-term insurance premiums were not subsidized by the state or the employer at that time. If the state grants the right to long-term insurance to interns via debt accrual, it essentially places the remaining premium cost of those years on the individual. However, this cost transfer is insufficient to mitigate the pension burden. This burden should be completely assumed by the Treasury/SSI due to early retirement. Therefore, a solution that maintains financial discipline must necessarily narrow the scope and keep the number of early retirements at a manageable level.

3.C. Financial Modeling and the Importance of Scope Restriction

Debt accrual models applicable to ensure financial stability create different effects on the SSI budget. This depends on the targeted mass. The most likely political strategy is the preference for a limited-scope model. This makes the long-term burden on the SSI manageable.

The table below analyzes the cost effects of possible debt accrual models:

Model	Scope and Target Audience	Premium Calculation Basis	Estimated Individual Debt Accrual Cost (1 Year)	SSI Early Retirement Burden (Estimate)
Model A: Full Retroactive Debt Accrual	All internship/apprenticeship periods (pre/post ’99)	Gross MW at Application Date (32%)	High (Challenges the individual)	Heavy and Long-Term (Unsustainable)
Model B: Phased Debt Accrual (EYT-like)	Only those with insurance start before 1999	Gross MW of Retroactive Period (32%)	Moderate (Due to narrow scope)	Limited and Manageable
Model C: State Subsidized Model	Mandatory Higher Education and Vocational High School Internships	Fixed Low Rate or Treasury Support	Low (Reduces personal financial risk)	Requires Balancing and Treasury Support

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Model B is consistent with the strategy of controlling costs. It targets the cohort where the crisis is most intensely felt, similar to the previous EYT regulation. This model offers the strongest compromise between meeting political demand and protecting the SSI’s financial balance.

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4. Possible Legal Targets and Detailed Solution Scenarios for 2026

Following the political debates in 2025, three basic solution scenarios are foreseen for the 2026 legislative year. These scenarios must be evaluated along the axes of legal justice, financial sustainability, and political applicability.

4.A. Solution Scenario 1: Narrow-Scoped Debt Accrual Model (Most Likely Political Consensus)

This scenario represents the most achievable target for 2026. Current political and financial constraints are considered.

Legal Target (2026 Q2): The addition of a temporary article to Article 41 of Law No. 5510 is targeted. This article regulates the debt accrual. This temporary article will strictly limit the scope. The debt accrual right will only be grantedto individuals. These individuals must have their first internship or apprenticeship insurance entry before September 8, 1999.

Implementation Mechanics: Debt accrual will be valid for the individual’s verifiable service periods. These periods must have been spent during the internship or apprenticeship. The period accrued will retroactively advance the insurance start date. This is done just like in military service or attorney internships. Thus, these people will meet the age and service year conditions. This allows them to benefit from the EYT regulation. The legal pragmatism of this model serves to alleviate the biggest political pressure. It does so by abandoning the principle of universal equality. It also aims for urgent financial stability.

4.B. Solution Scenario 2: Full Solution Focused on Legal Equality (Primary Demand of Victims)

This scenario directly responds to the fundamental demands of the Federation of Internship and Apprenticeship Victims.

Legal Target (2026): All internship and apprenticeship start dates must be accepted as the official insurance start date (ISD). This must apply without exception. A condition of retroactive premium payment (debt accrual) is required. This will completely eliminate legal inequality.

Risk Analysis: This model aligns with the “Full Insurance Right” demand. Yet, it carries two serious risks. First, it would require completely ignoring the Supreme Court’s complex jurisprudence on the school and workplace distinction. Second, and more importantly, an expanded early retirement right covering all cohorts would raise the financial burden on the SSI to unacceptable levels. This situation has the potential to destabilize the budget balance. It would multiply previous EYT costs. Therefore, Scenario 2 is not considered financially realistic for the 2026 legislative period.

4.C. Solution Scenario 3: Hybrid Model and Phased Implementation (Financial Balance Focused on Law No. 3308)

This scenario aims to maintain the scope restriction of Scenario 1. It also seeks to ease the debt accrual cost on individuals. Furthermore, it aims to increase legal justice.

Key Differentiation and Financial Balance:

• Distinction by Internship Type: Mandatory interns under Law No. 3308 were not included in the employer’s personnel count. Employers were exempted from long-term premium obligations. In this case, the state (Treasury) must subsidize a portion of the long-term premium share. This premium was not paid by the employers in the past.
• Voluntary Interns: The debt accrual costs for individuals who are not covered by mandatory internship or who work voluntarily must be fully covered by themselves.
• Payment Facilities: The high cost of debt accrual necessitates the introduction of mechanisms. These include long-term, low-interest, or interest-free installment plans. This ensures that individuals can use this right. This mechanism will secure the access of low-liquidity victims to their rights. It also protects the SSI’s debt accrual income.

This hybrid model focuses on the segment most in need. It also makes the debt accrual right practically usable. Thus, it preserves the SSI’s one-time revenue stream and manages political pressure.

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5. Conclusion, Integrated Policy Recommendations, and Action Plan

5.A. Integrated Policy Recommendations

Based on the legal, social, and financial analyses performed, an integrated model is the most balanced and applicable solution for 2026. This model combines restricted scope with individual financial support.

1. Scope and Restriction Priority: The legal regulation target for the second quarter (Q2) of 2026 must absolutely target the cohort with internship/apprenticeship insurance start before 1999 (Scenario 1). This ensures the priority of resolving the largest social victimization. It also protects the SSI’s financial structure.
2. Financial Access Assurance: Financial relief mechanisms must be simultaneously implemented. These are stated in Scenario 3. Examples include long-term installment plans and Treasury subsidies for mandatory interns. This increases the applicability of this restricted debt accrual right. The risk of the right not being used due to high cost is neutralized.
3. Forward-Looking Structural Solution: A permanent change must be made in Laws No. 5510 and 3308 to prevent the recurrence of victimization. This applies to all new mandatory internship periods starting from 2026. This change must mandate the inclusion of the internship period within the scope of at least a minimum long-term insurance premium.
4. Administrative and Legal Clarity: For smooth implementation, the new law must explicitly override or legally codify the Supreme Court’s complex jurisprudence on counting days during the internship period. The entire internship period must be accepted via debt accrual. This must be done without regard to the documented training calendar.

5.B. Priority Legal Regulation Calendar for 2026

The implementation of the following legal calendar is advised to ensure the effectiveness of the policy recommendations:

2026 Quarter	Phase	Action Detail
Q1	Preparation and Financial Authorization	The final numerical analysis of the target audience (pre-1999) must be completed. Finalized financial projections of debt accrual revenues and early retirement expenses must be approved by the Ministry of Treasury and Finance.
Q2	Legislative Commencement	The draft amendment to Law No. 5510 (addition of a Temporary Article) must be prepared. It must be submitted to the TGNA Planning and Budget Committee. The proposal must only include the pre-1999 cohort and the installment mechanism.
Q3	Enactment and Official Gazette	The law must be accepted by the Parliament’s General Assembly. It must enter into force by publication in the Official Gazette.
Q4	Implementation	Debt accrual applications must be started by the SSI. Debt accrual amounts must be determined. The technical infrastructure of the installment mechanisms must be activated.

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5.C. Implementation Risks and Impact Analysis

The implementation of the expected limited solution scenario brings various risks.

Political Risk: Limiting the scope of the solution to before 1999 may cause a new political crisis and protest wave. This will be generated by other excluded victim groups. These groups include apprenticeship insurance victims and those who interned after 2000. The increased pressure from victim associations in 2025 may turn into protests in 2026 if they are excluded.

Financial Application Risk: Setting debt accrual costs at a high rate over the 2026 gross minimum wage may exceed the individuals’ ability to pay. The right to debt accrual may remain only on paper. This happens if the installment and subsidy mechanisms (Scenario 3) are not implemented effectively.

Legal Risk: The regulation may be carried to the Constitutional Court. The distinction made between vocational high school interns and attorney interns regarding debt accrual may be debated. This relates to the Principle of Equality. The justification of the bill must clearly present the reasons for this distinction. This will strengthen its legal durability.

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