The Regulation never uses the word "trainee". The answer emerges from reading two provisions together.
First Obstacle: Not on the Title Lists
Chapter Five of the Regulation (Arts. 19-27) enumerates, for each type of publication, the titles eligible for a press card. "Trainee" does not appear on those lists.
Second Obstacle: The Six-Month Professional Work Document
Art. 28/1: during the application it is mandatory to upload to the system a passport photograph and a document evidencing at least six months of professional work.
Third Condition: A Contract Conforming to Law No. 5953
Art. 8/1-f: the applicant must have concluded a contract conforming to Law No. 5953 and, save for force majeure, work without a break of more than one month from the date of leaving a job.
Art. 10 of Law No. 5953 is meaningful here: for those entering the profession for the first time the probation period is at most three months, and during it either party may terminate the employment contract without notice or compensation. But the same article provides that at the end of the probation period the contract must be made in writing.
What the Commission Looks At
Art. 35/2: the Commission decides by assessing the applicant's qualifications, professional work, published output, awards and the qualities of the media outlet they belong to.
Meeting the conditions gets you over the threshold; the card is determined by the Commission's assessment. For someone new to the profession that assessment is naturally made on a thinner file.
Quota Is Also a Limit
Even where the conditions are complete, no card can be issued if the quota is full. Under Art. 27/2, for internet news sites:
| Employees insured under Law No. 5953 | Cards that may be issued |
|---|---|
| Four | Licence holder / representative + four employees |
| Five to nine | Licence holder / representative + nine employees |
| Ten and above | No quota limit is applied |
You can work out your quota in the quota calculation guide.
Working Without a Card Is Not Prohibited
The card is not a condition of doing journalism. Art. 3 of Law No. 5187 says the press is free, and Art. 5 of the Regulation defines the card as an identity document. We cover this in journalism without a press card.
Summary
- There is no "trainee" title in the Regulation.
- An application requires a document evidencing at least six months of professional work and a contract conforming to Law No. 5953.
- A card cannot be obtained in the capacity of a trainee.
- Once the probation period is complete, a written contract is made and six months of work has accumulated, an application can be made if the role is on the title lists.