It is worth reminding that, in accordance with Article 198 of the Labor Code of the Russian Federation, an Employer is a legal entity (organization) has the right to conclude an apprenticeship agreement with a job seeker or with an employee of this organization for receiving education on-the-job or off-the-job.

As follows from the provisions of Article 207 of the Labor Code of the Russian Federation, if the student, upon completion of apprenticeship, without good reason, does not fulfill his/her obligations under the agreement, in particular, does not start work, he/she, at the request of the employer, shall refund to it the scholarship received during the apprenticeship, and shall also reimburse other expenses incurred by the employer in connection with with apprenticeship. At the same time, the rules of labor legislation do not contain provisions that determine the maximum amount of expenses that can be recovered from an employee who has not fulfilled his/her obligations under the apprenticeship agreement, for example, who has not worked an agreed period of time. In practice, employers assume that they are entitled to reimbursement of the above expenses in full. At the same time, according to the position set out in Ruling No. 88-15512/2022 of the 8th Court of Cassation of General Jurisdiction dated August 11, 2022, this approach worsens the position of the employee in comparison with the rules of the labor legislation. According to the court of cassation, in this case, the employee shall compensate the employer for the expenses incurred for the training of the employee, in proportion to the hours worked.