What Are TRAPs And Why States Are Banning Them

Training Repayment Agreement Provisions, or TRAPs, are clauses in employment contracts that allow employers to bill workers for the cost of job training if they leave before a set period. These repayment amounts can range from several thousand to tens of thousands of dollars, regardless of whether the training provided has lasting value to the employee.

An investigation by the Student Borrower Protection Center (SBPC) found that major employers use TRAPs in industries that together employ more than one-third of private-sector workers. The report identified their increasing presence in health care, trucking, retail, and other service sectors.

The SBPC described TRAPs as part of a broader “shadow student debt” market – financial obligations that resemble student loans but arise from employment contracts rather than traditional credit products. In many cases, workers are not fully informed of these provisions when they sign their job offers or training agreements.

A Financial Burden On Workers

In practice, TRAPs often act as penalties for quitting. Nurses in Texas have been billed thousands of dollars for leaving hospital jobs before completing two-year commitments. Truck drivers have reported debts of up to $6,500 for exiting companies that advertised “free training” programs but delivered little instruction or unsafe conditions. Pet groomers at major retail chains have faced repayment demands of up to $5,000 for training programs that were promoted as no-cost employment benefits.

The debt can follow workers long after they leave. Some employers pursue collection through third-party agencies, report the debt to credit bureaus, or withhold final paychecks. Because these agreements are typically drafted by the employer, the repayment terms can include high interest rates, legal fees, or administrative charges that can exceed the actual cost of the training.

This debt structure reduces workers’ ability to change jobs, negotiate higher pay, or report unsafe or discriminatory conditions. Researchers at Loyola Law School have found that TRAPs may have stronger deterrent effects on worker mobility than traditional non-compete clauses because they impose a financial penalty rather than a career restriction.

How TRAPs Effectively Replace Non-Compete Agreements

Employers have increasingly turned to TRAPs as states tighten restrictions on non-compete clauses. While non-competes prohibit a worker from joining a competitor, TRAPs impose a financial barrier to leaving any job (you have to repay those “training costs”). 

The result is a labor market where employees may technically be free to change jobs but face heavy debt burdens if they do. Economists have linked such restrictions to lower wages and less competition among employers, particularly in industries already marked by high turnover.

How States Are Responding

Federal regulators began to address TRAPs and related non-compete agreements in the early 2020s. The Federal Trade Commission’s 2024 non-compete rule sought to prohibit both types of restrictive employment clauses nationwide. That effort stalled in 2025 after the FTC withdrew its defense of the rule in court, leaving regulation largely to the states.

In response, several states have advanced their own protections. This year, California lawmakers approved AB 692, which would prohibit employers from using debt or repayment threats to deter workers from leaving their jobs. The bill awaits Governor Gavin Newsom’s signature.

If enacted, California would join a list of states that have taken similar action. Those include New York, which passed the Trapped at Work Act banning TRAPs statewide; Colorado, which prohibited hospitals and health care staffing firms from charging medical workers for leaving; and Indiana, which limited stay-or-pay clauses in physician contracts. Wyoming, Nevada, Vermont, Massachusetts, Ohio, and Washington have also introduced or passed comparable legislation.

These state measures collectively mark the broadest movement against TRAPs since they first became common in the 1990s.

Industries Most Impacted

Health care has seen one of the most widespread uses of TRAPs. Hospitals and staffing agencies have required newly licensed nurses to sign contracts obligating them to stay for up to two years or repay thousands of dollars. The SBPC documented cases where repayment demands ranged from $5,000 to $50,000, even when the training provided was basic orientation or introductory coursework.

In the transportation sector, large trucking firms have relied on TRAPs to retain drivers. Workers recruited with promises of free commercial driver’s license programs often discover after enrollment that leaving early triggers substantial debts. Court cases against trucking companies have revealed that training fees charged to workers often exceeded the company’s actual costs by thousands of dollars.

Retail and service employers have also used TRAPs disguised as tuition or training benefits. Pet retailers, fast-food chains, and banks have offered “education assistance” or “paid training” programs that later require repayment if the worker leaves within six to twelve months. These provisions have created situations where low-wage employees must continue working despite poor conditions to avoid new debt.

What Workers Can Do

Employees considering new job offers need to review all documentation for repayment, reimbursement, or “training cost” clauses. State labor departments and legal aid organizations can help determine whether such agreements are enforceable under local law. Unions and worker advocacy groups are also pushing for the inclusion of “TRAP-free” provisions in collective bargaining agreements.

Transparency requirements (such as mandatory disclosure of all training costs and repayment terms before hiring) could reduce the likelihood that workers unknowingly take on employment-related debt.

If California enacts AB 692, it would become the first state to pass new restrictions on TRAPs following the federal government’s withdrawal from enforcement. 

The broader trend indicates a shift toward state-level governance of workplace mobility and consumer debt issues. With more industries adopting repayment clauses, regulators and legislators are seeking to ensure that job training does not become another pathway into long-term debt.

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