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Overview of workplace representation across the EU

A European overview of various channels (works council, trade union) of employee workplace represenation, including minimum thresholds required to activate the workers' rights to representation.

Workplace representation in Europe, 2014

     
           
 

Through employees representatives

Through union bodies

Main employee representation at workplace through:

Works council or
employee representative

Threshold

Union delegation or
union representative

Threshold a)

Austria

X

From 5 employees.

There is no direct trade union representation in the workplace. But in most cases the unions play a crucial part in the works councils' effective operation.

Works council.

Belgium

X

From 101 employees.

X

Depends on union agreement.

Union and works council – but union dominates.

Bulgaria

X

No threshold / from 20 or 50 employees. b)

X

Depends on union agreement.

Union – but law also provides for the election of employee representatives.

Croatia

X

From 20 employees.

X

Depends on union agreement.

Union and works council – but where no works council exist unions can take over its rights and duties.

Czech Republic

X

No threshold.

X

Depends on union agreement.

Union – but works council can be set up as well.

Denmark

X c)

From 35 employees.

X

In most agreements the right to elect a trade union representative starts once there are more than 5 employees in the workplace.

Union – but employee groups from outside the union can be represented in the structure.

Estonia

X

No threshold.

X

Depends on union agreement.

Union – but since 2007 employee representatives can be elected as well.

Finland

X
(if there are no union representatives)

From 20 employees.

X

Each workplace has a trade union representative.

Union

France

X
(two bodies: employee delegates / works council)

From 11 employees / from 50 employees.

X

From 50 employees.

Union and works council / employee delegates – but union normally dominates if present.

Germany

X

From 5 employees.

There is no direct trade union representation in the workplace. But the unions have a major influence on the works councils' operation.

Works council.

Greece

X

From 50 employees (from 20 employees if there is no union body).

X

Depends on union agreement.

Union – works councils exist in theory but not often in practice.

Hungary

X

From 51 employees.

X

Depends on union agreement.

Union and works council.

Ireland

X d)

From 50 employees.

X

Depends on union agreement.

Union – but other structures are possible and since 2006 these can be triggered by employees.

Italy

X

From 16 employees.

The elected employee representatives are essentially union bodies.

Union – although largely elected by all employees.

Latvia

X

From 5 employees.

X

Depends on union agreement.

Union – although possible to elect other representatives since 2002.

Lithuania

x (If there are no union representatives)

No threshold.

X

Depends on union agreement.

Union – or works council (since 2003) if there is no union.

Luxembourg

X

From 15 employees.

Unions have important rights in this structure and the majority of employee representatives are union members.

Works council / employee delegates (with employee delegates replacing the works council since 2013).

Malta

X e)

From 50 employees.

X

Depends on union agreement.

Union.

Netherlands

X

From 50 employees.

In many organisations collective agreements give trade unions at work specific rights.

Works council.

Poland

X

From 50 employees.

X

Depends on union agreement.

Union and works council –
but most works councils are in unionised workplaces.

Portugal

X

No threshold.

X

Depends on union agreement.

Union – works councils exist in theory but less frequently in practice.

Romania

X (If there are no union representatives)

From 21 employees.

X

Depends on union agreement.

Union – other employee representation is rare.

Slovak Republic

X

From 50 employees.

X

Depends on union agreement.

Union and works council (since 2003).

Slovenia

X

From 21 employees.

X

Depends on union agreement.

Union and works council.

Spain

X

From 11 employees.

X

From 250 employees.

Works council – although dominated by unions.

Sweden

No works council.

X

Depends on union agreement.

Union.

United Kingdom

X f)

From 50 employees.

X

Depends on union agreement.

Union – but other structures are possible and since 2005 these can be triggered by employees.

   

Norway

X

From 100 employees (obligatory).

X

The number of union representatives is linked directly to the number of union members in the company who belong to each union confederation.

Union – “works councils” exist in some companies but their role is to improve competitiveness.

Switzerland

X

.

At least some of the employee representatives are members of a trade union and/or advised by trade unions.

Works council.

(a) Often there is no threshold by law for union representatives, the number then depends on the rules of the union. However, there are often legal limits on the number of union representatives who can benefit from specific legal rights and job protections. ‒
(b) There are no specific rules on the numbers or thresholds for employee representatives elected to represent employees’ social and economic interests. However, the legislation is more precise where employee representatives are elected for the purposes of information and consultation. These representatives should be elected in companies employing 50 or more employees, or in workplaces employing 20 or more. ‒
(c) The Danish equivalent of the works council is the cooperation committee. ‒
(d) The legislation (passed in 2006 as a result of the EU directive on information and consultation) does not require all companies covered by it to establish employee bodies for information and consultation. The process only begins if 10% of employees, with a lower limit of 15 and an upper limit of 100, ask for information and consultation rights or the employer takes the initiative. Negotiations then start between the employer and employee representatives, who automatically include union representatives if the employer recognises unions and they represent at least 10% of the workforce. ‒
(e) In Malta it is the union that normally represents the employee at workplace level. But EU directives have led to new arrangements for non-unionised employees. The 2006 legislation, requiring the setting up of information and consultation structures, has applied to companies with 50 or more employees from March 2008 and applied to larger companies before that date. The legislation does not set out the precise numbers of information and consultation representatives, only that as well as the representatives of the recognised union – number unspecified – “no more than one representative” should be elected for each category of employees not represented by a recognised union. ‒
(f) The Information and Consultation of Employees Regulations 2004 give employees in businesses with 50 or more employees the right to require the employer to set up an employee information and consultation forum, which has the right to be informed and consulted on a regular basis about issues in the business for which they work. Consultative bodies established under these Regulations are typically called information and consultation bodies, or employee consultation forums, and have some similarities to continental European style National Works Councils, but are considerably less onerous from an employer’s perspective.

Sources: European Worker Participation Competence Centre (EWPCC): http://www.worker-participation.eu/National-Industrial-Relations/Countries (July 2015) and
Baker & McKenzie (2014), The Global Employer: Focus on Trade Unions and Works Councils, Key Workplace Documents, Cornell University ILR School.

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