I take your points but I disagree across the board.
Yes technically a company can of course pay minimum wage. The point of a regulator though is to ensure that they do not pay below minimum wage. We have employment and labour law that are supposed to draw a line as to when the employer pays for training. My understanding is that the OCC and LIFUS are non-delegable if wrapped up with the type rating then this also should be the case. So as soon as an airline charges for training and includes these elements in that relationship they are effectively charging for employment until the relationship fundamentally changes. Just because the company puts a paper shell between itself and the employee that doesn’t mean everyone should accept this evasion of law and workers rights… that is where the regulators should … regulate.
The law doesn’t operate in silos as Ryanair it seems would have everyone believe. Aviation, labour and employment law intersect.
You wouldn’t expect a pilot to pay for a new type rating if the airline changed its fleet… so why are we expecting new entrants who are the most vulnerable amongst us who already have likely 100k of debt… to take on more? This then gets into the Ghent study where such vulnerable people are not likely to make sound decisions when pay comes into reporting fatigue etc.