Is your consultation plan ready for every country it touches?

Pick the countries your change lands in and what kind of change it is. You get, country by country, who has to be at the table, what starts the clock and how long it runs. Then the questions only your own landscape can answer.

Fifteen countries, four kinds of change and the European Works Council. Orientation, not legal advice: each card names its sources, reviewed 2 October 2026.

Start the check Get it as a pack

Tap a country to add it to the check.

Where does the change land?

Choose every country with employees affected. The statutes differ more than a group policy suggests.

What kind of change?

Do you have a European Works Council?

An EWC can be requested where a group has at least 1,000 employees in the EEA and at least 150 in each of two countries.

Your orientation

Choose at least one country above to see who has to be consulted, and when.

Count the thresholds the way each country counts them (per establishment or per region, over 30, 60, 90 or 120 days), start the longest clock first, and keep the announcement consistent: a decision presented as final in one country is evidence that consultation elsewhere came too late.

Transfers of undertaking carry employees, agreements and often the consultation bodies with them. Where the law asks for information to representatives before the signing (Italy, Poland, the Netherlands), sequence it in; and keep the measures you plan after the transfer out of the decision until they have been consulted.

In works council countries a monitoring-capable system is a consent matter, not an information one; in the Nordics it is a negotiation; in the UK and Ireland it is a data protection exercise with consultation where you have agreed to it. A group rollout therefore has several different start lines. From 2 December 2027 the EU AI Act adds a duty to inform workers’ representatives and affected workers before a high-risk AI system is used at work.

Policies that change contracts need each employee’s agreement in most countries, on top of any collective step. Sector agreements in Belgium, Italy, Finland, Sweden, Austria and Denmark may already settle the matter, and a group policy that departs from them does not apply there.

Austria

A works council (Betriebsrat) from five employees, with graduated rights from information to consent. Sector collective agreements (Kollektivverträge) cover almost everyone, so the union is in the room through the agreement; the economic rights step up at 150 and 300 employees.

What starts it
Operational changes (closure, cutbacks, relocation, mergers) must be notified to the works council early enough for it to assess and comment, and consulted at its request; in establishments of 20 or more a social plan can be imposed by the conciliation board where the change brings substantial disadvantages. Collective redundancies (within 30 days: 5 in a workforce of 20 to 100, 5% in 100 to 600, 30 above 600, or 5 employees aged 50 or more) must be notified in writing to the employment service (AMS).
The clock
At least 30 days between the AMS notification and the first notice. The works council must also be informed before each dismissal and has a week to respond.
Watch
Notices given before the 30 days have run, or without the works council being informed, are void. The works council can challenge dismissals as socially unjustified.
What starts it
Mergers, outsourcing, moves and changes of organisation are operational changes with the same information and consultation duty, and a transfer of undertaking requires information of the works council (or the employees) beforehand.
The clock
No statutory period for the consultation itself; the works council’s week per dismissal and the 30-day AMS rule set the floor where jobs go.
Watch
Economic committee rights apply from 300 employees (150 at the works council’s request); expect questions at that level in larger groups.
What starts it
Any system that collects employee data beyond the basics, and any control measure that touches human dignity (CCTV, monitoring software, performance tracking), needs a works agreement. For the dignity-affecting kind the works council’s consent cannot be replaced by the conciliation board or a court.
The clock
Allow one to three months to negotiate the works agreement; a framework agreement on IT systems speeds up later tools.
Watch
Monitoring introduced without the agreement is void and the data unusable, with data protection exposure on top.
What starts it
Working-time schedules, flexitime, remuneration systems, performance-related pay, remote-working rules and company rules of conduct are works agreement matters; some the works council can enforce through the conciliation board.
The clock
Before implementation; in practice one to two months for a works agreement.
Watch
The sector collective agreement sets the floor and often the detail. Read it before drafting.
Sources for Austria, reviewed 2 October 2026

Belgium

A works council from 100 employees, a committee for prevention and protection at work from 50, and a union delegation at thresholds set by your joint committee. Where there is no works council, the union delegation (or, failing that, the committee) takes over its information and consultation role. Social elections are held every four years, next in May 2028.

What starts it
A collective dismissal (within 60 days: 10 in a workforce of 20 to 99, 10% in 100 to 299, 30 from 300) starts the Renault procedure: a formal information and consultation phase with the works council, then notification to the regional employment service and a 30-day waiting period before notice can be given.
The clock
The consultation phase has no fixed length and routinely runs weeks to months; the 30-day wait follows, and the regional service can extend it by up to 30 days. Budget three to six months.
Watch
Notices given before the procedure is complete are void. Closing an undertaking brings its own rules and indemnities on top.
What starts it
The works council (or the union delegation in its place) must be informed and consulted beforehand on decisions with important consequences for employment or the organisation: mergers, restructuring, transfers, relocations and closures. A transfer of undertaking requires prior information of the representatives in its own right.
The clock
Information comes before the decision is made public and before implementation; where the change brings new technology with important consequences, the three-month rule below applies.
Watch
The joint committee’s own agreements often add steps. Union delegations negotiate, which a works council does not.
What starts it
New technology with important consequences for employment, work organisation or working conditions (at least 10 workers and half of a category, in companies of 50 or more) requires written information to the works council, or failing that the union delegation or committee, at least three months before, and consultation. Monitoring of email and internet use, and camera surveillance, are governed by their own national agreements.
The clock
Three months’ notice is the rule for technology with important consequences; monitoring measures need prior information of the works council and of the employees.
Watch
Belgian unions treat workplace monitoring as a bargaining matter, and a change to the work rules goes through the works council.
What starts it
Changes to the work rules (règlement de travail, arbeidsreglement), which cover working time, pay dates and discipline, must be agreed in the works council; without one, a posting and comment procedure applies. Working-time schemes often need a company agreement with the unions.
The clock
Count the works council cycle plus the sector agreement’s position: at least one to two months.
Watch
Pay is framed by sector agreements and the wage norm; a group policy that departs from them does not apply here.
Sources for Belgium, reviewed 2 October 2026

Denmark

No statutory works councils. Cooperation committees (samarbejdsudvalg) under the DA and FH cooperation agreement in companies of 35 or more where the agreement applies, union shop stewards, and representatives elected for a process where there is no agreement.

What starts it
Collective redundancies (within 30 days: at least 10 in a workforce of 21 to 99, 10% in 100 to 299, 30 from 300) require negotiation with the employees or their representatives with a view to avoiding or reducing them, and written notification to the Regional Labour Market Council.
The clock
Dismissals take effect no earlier than 30 days after the council is notified, eight weeks where at least half the staff of a workplace of 100 or more are dismissed. A second notification follows the negotiations.
Watch
Cooperation agreements add information duties before major changes, and many collective agreements add their own procedure.
What starts it
A transfer of undertaking requires information to the representatives (or the employees) in reasonable time before, and negotiation where measures are planned. Under the cooperation agreement, major changes in production, organisation or staffing are discussed in the committee before the decision.
The clock
Inform in reasonable time; the cooperation committee meets as needed, typically weeks ahead.
Watch
Collective agreements transfer with the undertaking unless disclaimed within the set period.
What starts it
Monitoring and control measures must be proportionate and employees informed before they start, and most cooperation and collective agreements in the private sector require advance information of the employees, weeks ahead, before a new control measure takes effect. New technology that changes work organisation goes to the cooperation committee.
The clock
Advance information under the agreement that applies, and the cooperation committee before the decision.
Watch
The data protection agency expects a documented purpose and proportionality. Camera surveillance follows the TV surveillance act.
What starts it
Working-time and policy changes are largely a matter for the collective agreement and the cooperation committee, which agrees principles for working conditions, welfare and the use of personal data. Contractual changes need notice equal to the notice period.
The clock
The agreement’s timetable; material changes to contracts take effect after the individual notice period.
Watch
The Salaried Employees Act gives long notice periods. A change imposed with too little notice is a dismissal.
Sources for Denmark, reviewed 2 October 2026

Finland

Shop stewards (luottamusmies) under the generally binding collective agreement, or an elected representative, under the Co-operation Act. Since 1 July 2025 the Act’s full regime applies to employers of 50 or more, with lighter duties from 20 to 49, and employees sit on a governance body from 150.

What starts it
Change negotiations (muutosneuvottelut) are mandatory before deciding on redundancies, lay-offs or reductions to part-time work. Employers of 20 to 49 must negotiate only when reducing at least 20 employees within 90 days. The employment authority must be told without delay when at least 10 employees face dismissal.
The clock
A written negotiation proposal at least five days before negotiations start; then at least three weeks of negotiation where 10 or more employees are affected, otherwise at least seven days, unless agreed otherwise.
Watch
The negotiations must cover the grounds, the effects and the alternatives before the decision; a breach brings compensation for each employee affected.
What starts it
A transfer of business, merger, outsourcing or material change in work organisation is a matter for change negotiations (or, at smaller employers, information to the representatives), and both employers inform about a transfer.
The clock
Negotiations before the decision, with the three-week or seven-day minimum where employment is affected; transfer information in good time.
Watch
The continuous dialogue, the regular meetings with the representative, is where these come up first. Surprises there breach its spirit.
What starts it
Camera surveillance, email access and technical monitoring are governed by the Act on the Protection of Privacy in Working Life: purpose, methods and use are handled in co-operation negotiations (or by informing employees at smaller workplaces) before the system is taken into use. AI tools that assess staff come under the same regime plus GDPR.
The clock
Dealt with before introduction, through the continuous dialogue or change negotiations as appropriate.
Watch
The Data Protection Ombudsman’s workplace guidance is specific. Aptitude testing and health data have their own limits.
What starts it
Changes to working-time arrangements, workplace rules and personnel plans are handled in the continuous dialogue; a material change to employment terms needs change negotiations where it affects staff, and most working-time flexibility sits in the collective agreement.
The clock
Before the decision; the collective agreement’s timetable for working-time schemes.
Watch
Generally binding collective agreements apply even to non-member employers. A group policy must fit them.
Sources for Finland, reviewed 2 October 2026

France

A social and economic committee (CSE) is mandatory from 11 employees; from 50 it carries the full information and consultation role, its own budget and the right to appoint an expert at your cost. Union delegates negotiate agreements, and in groups a central CSE and a group committee may need consulting as well.

What starts it
Every economic dismissal involves the CSE. From 10 dismissals in 30 days in a company of 50 or more, an employment protection plan (PSE) is mandatory, either negotiated with majority unions or set unilaterally, and validated or approved by the labour administration (DREETS).
The clock
The CSE’s consultation is framed: two months for fewer than 100 dismissals, three months for 100 to 249, four months for 250 or more, counted from the first meeting. DREETS then has 15 days to validate an agreement or 21 to approve a unilateral plan.
Watch
Fewer than 10 dismissals still means CSE consultation, a redeployment obligation and notification to DREETS. The CSE’s expert lengthens the timetable and the paper trail.
What starts it
A reorganisation, transfer of activity, outsourcing or merger is a project affecting the company’s organisation, management or general running, on which a CSE of 50 or more must be consulted before the decision, with the full information handed over first.
The clock
One month for the CSE’s opinion by default, two months if it appoints an expert, three where the central and local committees are both consulted; silence counts as a negative opinion. A transfer of undertaking carries the contracts across automatically.
Watch
Consult before the decision is final: a court can suspend a project consulted on too late. Changes to contracts after a transfer need their own process.
What starts it
Introducing new technology, or any significant change to working conditions, health and safety or equipment, requires prior CSE consultation. Employee monitoring must be declared to the CSE and to each employee before it starts, and the CNIL’s rules apply.
The clock
One month for the opinion, two with an expert (the CSE can appoint one for important projects introducing new technology). In companies of 300 or more the health, safety and working conditions commission is involved as well.
Watch
Data collected by a device the employees were not told about cannot be used against them. AI tools that profile or evaluate staff attract the CSE consultation and, from 2 December 2027, the AI Act’s information duty.
What starts it
Changes to working time, pay policy, remote working, holidays and internal rules go to the CSE, and many need a collective agreement with the unions as well (annual working-time arrangements, for example). The recurring consultation on social policy covers them too.
The clock
One month for the CSE’s opinion; longer where a company agreement has to be negotiated.
Watch
A change to the employment contract itself (pay, hours, sometimes place) needs each employee’s written agreement, and refusing is not misconduct.
Sources for France, reviewed 2 October 2026

Germany

A works council (Betriebsrat) can exist in any establishment with five or more employees, and most German sites of any size have one. From more than 20 employees the operational-change rights apply, from more than 100 an economic committee sits alongside, and employees take one third of the supervisory board from 500 employees and half from 2,000.

What starts it
Closing, moving, merging or significantly cutting an establishment with more than 20 employees is an operational change (Betriebsänderung): the works council must be informed fully and in good time, and a reconciliation of interests (Interessenausgleich) negotiated before anything is implemented. A social plan (Sozialplan) can be imposed through the conciliation committee.
The clock
No fixed period, but the reconciliation of interests must be pursued until it is exhausted, in practice weeks to months. The collective redundancy notification to the employment agency (within 30 days: more than 5 dismissals in an establishment of 21 to 59, 10% or more than 25 in 60 to 499, 30 or more from 500) must be filed before any notice is given, and the works council must be heard before each individual dismissal, with a week to respond.
Watch
Notices given before the notification, or before the works council hearing, are void. Plan the sequence: inform, negotiate, notify, then dismiss.
What starts it
Splitting or merging establishments, outsourcing a function or changing the organisation fundamentally is an operational change in establishments with more than 20 employees, with the same reconciliation of interests and social plan machinery. A transfer of undertaking also requires written information to each employee about the transfer and its consequences beforehand; they may object within a month.
The clock
Allow weeks to months for the reconciliation of interests. In enterprises with more than 300 employees the works council can call in an adviser at your cost.
Watch
The transfer itself needs no works council consent; the measures around it (new working time, systems, locations) usually do.
What starts it
Any technical system that can monitor behaviour or performance, which includes most HR systems, collaboration tools and AI assistants, is subject to the works council’s full co-determination: it cannot be introduced or changed without agreement or a conciliation committee ruling. Personnel questionnaires and selection guidelines need consent too.
The clock
Negotiating a works agreement (Betriebsvereinbarung) on a new system takes, in practice, two to six months. A framework agreement on IT or AI shortens later rollouts to weeks.
Watch
The data protection impact assessment and the works agreement belong together: the works agreement is often the legal basis for processing. From 2 December 2027 the AI Act adds a duty to inform the works council and affected employees before a high-risk AI system is used at work.
What starts it
Working-time arrangements, pay structures and bonus schemes, holiday rules, conduct rules and remote-working arrangements are co-determined: the works council must agree, or the conciliation committee decides.
The clock
No statutory period; nothing can be implemented until there is agreement, so start months before the intended effective date.
Watch
Where a collective agreement (Tarifvertrag) already regulates a matter, the works council cannot: check the agreement first.
Sources for Germany, reviewed 2 October 2026

Ireland

No works councils by default. Trade unions where recognised, otherwise representatives elected for the process. Employees of a 50-plus undertaking can trigger a standing information and consultation forum under the 2006 Act (10% of staff, at least 15 and at most 100 people).

What starts it
A collective redundancy (within 30 days: 5 in a workforce of 21 to 49, 10 in 50 to 99, 10% in 100 to 299, 30 from 300) requires consultation with employee representatives and written notice to the Minister for Enterprise, Trade and Employment.
The clock
Consultation at the earliest opportunity and at least 30 days before the first notice of dismissal. The Minister’s notification also at least 30 days before the first dismissal takes effect.
Watch
Dismissing before the 30 days have run is an offence, and the 2024 Act strengthened employees’ position in insolvency redundancies. Collective agreements often add a longer process.
What starts it
A transfer of undertaking obliges both employers to inform representatives in writing and, where measures are envisaged, to consult them with a view to agreement. A reorganisation that leads to redundancies is caught by the collective rules above.
The clock
Information not later than 30 days before the transfer, and in any event in good time; consultation with a view to reaching agreement.
Watch
The WRC awards up to four weeks’ pay per employee for information failures. Terms cannot be worsened because of the transfer.
What starts it
No statutory consultation duty on a new system as such, but a standing forum must be consulted on decisions likely to lead to substantial changes in work organisation, and monitoring needs a data protection impact assessment and transparency under GDPR, with the Data Protection Commission’s guidance.
The clock
Your own forum or union agreement sets it; plan weeks, not days.
Watch
The Irish regulator leads for many global technology employers, and its expectations on employee monitoring are high.
What starts it
Contract changes need agreement, and a standing forum or union agreement brings consultation on changes to work organisation or contractual relations. Working-time and pay changes also run into sectoral orders in some sectors.
The clock
Agreement before the change; a union negotiation runs on its own timetable.
Watch
The WRC’s code of practice on employee involvement sets the expected standard for consultation.
Sources for Ireland, reviewed 2 October 2026

Italy

Workplace union representatives (RSA or RSU) in units with more than 15 employees, under the national sector agreement (CCNL) that applies to you. There is no works council: the CCNL and the territorial unions are your counterparts, and companies of 50 or more have statutory information and consultation duties on top.

What starts it
Five or more dismissals within 120 days in a company of more than 15 employees is a collective dismissal: written notice to the unions and the public bodies opens a union consultation, followed by an administrative phase if there is no agreement.
The clock
Up to 45 days at union level, then up to 30 days before the labour office (both halved where fewer than 10 employees are affected). Notices then follow within 120 days, unless agreed otherwise, and must state the selection criteria.
Watch
Procedural slips make the dismissals ineffective. Employees hired before and after 7 March 2015 have different remedies, so check hire dates.
What starts it
A transfer of an undertaking or business unit, where the transferor employs more than 15, requires written notice to the unions at least 25 days before the binding agreement; within seven days the unions can demand consultation, which must start within the next seven.
The clock
At least 25 days before signing, plus up to two weeks of consultation. The CCNL may add information duties for reorganisations and relocations.
Watch
Transfers that carve out a unit artificially are challenged routinely; the unions test whether it is a genuinely autonomous unit.
What starts it
Any equipment from which monitoring of employees could result, under the Workers’ Statute’s famous article 4, needs a prior agreement with the union representatives or, failing that, authorisation from the labour inspectorate. Tools used to perform the job and attendance systems are exempt but must be explained to employees, with data protection information.
The clock
Negotiating the union agreement takes weeks; an inspectorate authorisation, months. Nothing may be installed before.
Watch
Data gathered without the agreement cannot be used for any purpose, discipline included. The Garante has fined employers for email and GPS monitoring without it.
What starts it
Working time, shifts, pay structures and many policies are set by the CCNL and by second-level (company) agreements with the unions; a unilateral change outside the CCNL’s room is void. Information and consultation on changes in organisation follows the CCNL’s clauses and the statutory rules for companies of 50 or more.
The clock
Company bargaining runs on the CCNL’s timetable; allow one to three months.
Watch
Which CCNL applies is the first question in Italy. The answer sets pay, notice, consultation and the unions you deal with.
Sources for Italy, reviewed 2 October 2026

Netherlands

A works council (ondernemingsraad) is compulsory from 50 employees. From 10 to 49, an employee delegation (PVT) if a majority of staff ask for one, otherwise staff meetings. Trade unions come in for collective redundancies and the social plan.

What starts it
Twenty or more dismissals in one UWV region within three months is a collective redundancy: the unions and the UWV must be notified before anything proceeds, and the works council’s advice is required on the decision to reorganise.
The clock
A one-month wait after notifying the UWV before dismissal applications are handled, unless the unions declare they have been consulted. The works council’s advice comes first; if you do not follow it, a one-month standstill before implementation, during which it can appeal to the Enterprise Chamber.
Watch
Economic dismissals go through the UWV or a settlement agreement: plan for the permit route. Selection follows the reflection principle (afspiegeling).
What starts it
A significant reorganisation, transfer of control, outsourcing, major investment or group restructuring is on the works council’s advice list: advice must be requested in writing while it can still affect the decision.
The clock
No fixed period for the advice (often four to eight weeks in practice), plus the one-month standstill if the advice is not followed.
Watch
A transfer of undertaking is advice-bound on both sides; make the sale agreement conditional on the advice.
What starts it
Rules on processing employee data, and any facility that can observe attendance, behaviour or performance (AI tools included), need the works council’s consent. Without it the system cannot be used, unless the sub-district court substitutes its consent.
The clock
Allow two to three months for the consent request, the works council’s questions and its decision; a refusal adds a court step.
Watch
The Data Protection Authority expects the works council’s involvement to be documented. The DPIA and the consent request should reference each other.
What starts it
Working-time rules, holiday arrangements, pay systems, appraisal, training, remote-working policy, complaints procedures and health and safety policy all need the works council’s consent.
The clock
No statutory period; consent before implementation, so build in at least two months.
Watch
A policy already settled in the collective agreement (CAO) is outside the consent right. Everything else is in.
Sources for Netherlands, reviewed 2 October 2026

Norway

Elected employee representatives (tillitsvalgte) under the Working Environment Act and, where you are bound, the Basic Agreement between LO and NHO. Employees can demand a board seat from 30 employees and a third of the board from 50.

What starts it
Dismissing 10 or more employees within 30 days for reasons not related to them is a collective redundancy: consult the representatives as early as possible to seek agreement, and notify NAV. Undertakings of 50 or more must also inform and consult on decisions that materially change work organisation.
The clock
Notice periods do not start until 30 days after NAV is notified, and consultation comes before the decision. Basic Agreement companies add discussion with the shop stewards as early as possible.
Watch
Seniority is the default selection criterion under the Basic Agreement, and departures from it need objective justification. Dismissed employees keep a preferential right to new posts for a year.
What starts it
A transfer of undertaking requires information and discussion with the representatives as early as possible, and information to the employees. A reorganisation in an undertaking of 50 or more is consulted under the information and consultation rules.
The clock
As early as possible and before decisions; in practice weeks ahead.
Watch
Employees may object to the transfer. Document the discussion with the representatives.
What starts it
Control measures (monitoring, cameras, software that tracks work, AI tools that assess employees) must be objectively justified and proportionate, discussed with the representatives as early as possible, and explained to employees (purpose, consequences, duration) before implementation. Email and GPS monitoring have their own regulation.
The clock
Discussion with the representatives before the decision, information to employees before use, and periodic evaluation of the measure.
Watch
The Data Protection Authority (Datatilsynet) is active on workplace monitoring. A measure without the discussion breaches the Act.
What starts it
Working-time arrangements beyond the statutory frames need agreement with the representatives (or the Labour Inspection). Material changes to employment terms require notice equal to the notice period and are discussed with the representatives in undertakings of 50 or more.
The clock
Agreement before implementation; the notice period for contractual changes.
Watch
The Basic Agreement’s cooperation rules apply alongside the Act for its members.
Sources for Norway, reviewed 2 October 2026

Poland

Company trade union organisations (from 10 members) are the main counterpart. A works council (rada pracowników) can be set up at employers with at least 50 employees, though a representative union takes precedence where one exists. Without either, representatives elected for the process.

What starts it
Collective redundancies (employers of 20 or more; within 30 days: 10 where fewer than 100 employees, 10% in 100 to 299, 30 from 300) require consultation with the unions, or elected representatives, aimed at an agreement, and notification of the district labour office.
The clock
Written information to the unions and the labour office at least 20 days before an agreement is signed, and the agreement should be concluded within 20 days of that information. Dismissals take effect no earlier than 30 days after the office is notified of the outcome.
Watch
Individual dismissals of union members still need union consultation, with five days to respond. Statutory severance applies in collective redundancies.
What starts it
A transfer of a workplace or part of it requires written information to the unions, or to the employees where there are none, at least 30 days before the transfer. The works council must be consulted on changes in the organisation of work and the structure of employment.
The clock
At least 30 days before the transfer; works council consultation in good time, with the information needed to form an opinion.
Watch
Employees may leave within two months of a transfer, with the departure treated as the employer’s termination.
What starts it
Monitoring (video, email, other forms) must be set out in the collective agreement, the work regulations or a notice, and employees informed at least two weeks before it starts. The works council and the unions are consulted on the changes to work organisation a new system brings.
The clock
Two weeks’ notice to employees is the statutory minimum; agreeing the work regulations with the unions takes longer.
Watch
Email monitoring may not breach the secrecy of correspondence. The labour inspectorate and the data protection authority both check the regulations.
What starts it
Work regulations (working time, order, pay dates) are agreed with the company union organisations, and so are pay regulations. Changes to individual terms need a changing notice (wypowiedzenie zmieniające) with the notice period, and union consultation for members.
The clock
New work regulations take effect two weeks after they are announced, once agreed with the unions (or after 30 days without agreement).
Watch
Working-time systems and reference periods need union agreement, or employee representatives where there is no union, and notification to the labour inspectorate.
Sources for Poland, reviewed 2 October 2026

Spain

Staff delegates from 11 employees (and from 6 where the staff want them), a works council (comité de empresa) from 50, trade union sections alongside, with union delegates from 250. The representatives negotiate as a committee in the formal processes.

What starts it
A collective dismissal (ERE) is required when, within 90 days, terminations reach 10 in companies under 100, 10% in 100 to 299, or 30 from 300: a consultation period with the representatives, information to the labour authority and a report from the labour inspectorate.
The clock
Consultation lasts up to 30 days (15 in companies under 50), and dismissals cannot take effect sooner than 30 days after the authority was notified. Expect six to ten weeks end to end.
Watch
The documentation of the economic, technical, organisational or production grounds is examined closely; a thin file leads to the dismissal being declared null.
What starts it
Collective transfers of workplace, suspensions and reductions of hours (ERTE), transfers of undertaking and any substantial collective change all open a consultation period with the representatives. The works council is informed of mergers and reorganisations beforehand.
The clock
Fifteen days of consultation for substantial modifications and collective transfers, 15 days or fewer for an ERTE; the decision then takes effect seven days after it is notified.
Watch
Many collective agreements add their own steps. An agreement with the representatives cuts the litigation risk sharply.
What starts it
The works council has the right to be informed of the parameters, rules and instructions behind algorithms or AI systems that affect decisions on working conditions, access to employment or keeping it, profiling included (since 2021). Monitoring and devices are consulted as changes to working conditions, and the data protection law requires prior information to employees.
The clock
No fixed period beyond the quarterly information cycle; where the rollout changes working conditions substantially, the 15-day consultation applies.
Watch
Time recording is mandatory and its system is itself a consultation matter. The labour inspectorate takes algorithmic transparency seriously.
What starts it
A substantial change to working conditions (hours, schedules, shifts, pay systems, functions) affecting enough people is a collective modification: 15 days of consultation with the representatives, then seven days before it takes effect. Remote working needs a written agreement with each employee.
The clock
Fifteen days of consultation and seven days before effect for collective changes; 15 days’ notice to each employee for individual ones.
Watch
Employees affected by a substantial change may resign with compensation or challenge it; agreed changes stick better.
Sources for Spain, reviewed 2 October 2026

Sweden

No works councils. The trade unions you have a collective agreement with, and often those with members among your staff, are consulted under the Co-Determination Act (MBL). Employees also sit on the board from 25 employees where a collective agreement applies.

What starts it
Before deciding any important change to the business or to working conditions, redundancies included, the employer must negotiate with the unions on its own initiative. The public employment service must be notified of redundancies when at least five employees in a county are affected.
The clock
Negotiation first, decision after; no fixed period, but it must be genuine. The notice to the employment service must arrive two months ahead for up to 25 employees, four months for 26 to 100, six months for more than 100.
Watch
Selection follows last-in-first-out with the 2022 exemptions, and the unions negotiate the order list. Decisions taken before the negotiation attract damages.
What starts it
A transfer of undertaking, a reorganisation or outsourcing is an important change: negotiate with the unions before the decision. A transfer also carries the collective agreement across for a year unless it is replaced.
The clock
Negotiation before the decision; weeks rather than months if well prepared, longer when the union escalates to central negotiation.
Watch
The unions hold a veto on contractors where the contractor would breach the law or the agreement.
What starts it
Introducing or changing a monitoring system, camera surveillance or a new IT or AI tool is an important change to working conditions and is negotiated with the unions before the decision. GDPR applies with the data protection authority’s guidance.
The clock
Negotiation before the decision; allow several weeks. The union may request central negotiation.
Watch
Many collective agreements add detailed rules on monitoring and data. Check the agreement’s co-determination clauses.
What starts it
Working-time schemes, pay systems, remote-working rules and other policy changes affecting employees are negotiated with the unions beforehand. Working time is largely set by the collective agreement.
The clock
Negotiation before the decision; the collective agreement sets the pace.
Watch
There is no statutory minimum wage. Pay policy is a bargaining matter.
Sources for Sweden, reviewed 2 October 2026

Switzerland

Employee representation under the Participation Act is possible from 50 employees where the staff elect one. Many companies have none, and then the employees themselves are informed and consulted directly. Collective agreements (GAV, CCT) apply in some sectors.

What starts it
A collective dismissal (within 30 days: 10 in a workforce of 20 to 100, 10% in 100 to 300, 30 from 300) requires consultation of the representation, or of the employees, with a real chance to propose alternatives, and written notification to the cantonal employment office.
The clock
No minimum consultation period in law, but a reasonable one, typically two to four weeks, before notices; contracts end no earlier than 30 days after the cantonal notification. A social plan must be negotiated where an employer of 250 or more dismisses 30 or more within 30 days.
Watch
Skipping consultation makes the dismissals abusive (up to two months’ pay per employee). Where a collective agreement applies, the social plan is negotiated with the unions.
What starts it
A transfer of undertaking requires information of the representation (or the employees) in good time before the transfer, and consultation if measures affecting employees are planned. The Participation Act gives the representation information rights on matters employees need to know.
The clock
Information before the transfer, consultation in good time before the measures; in practice a few weeks.
Watch
Employees may refuse the transfer of their contract; plan for that in a carve-out.
What starts it
Monitoring systems designed to track behaviour are prohibited. Systems needed for other purposes (security, the performance of the work) must be proportionate and employees informed, and the revised data protection act requires transparency. Participation rights apply to health and safety matters.
The clock
Set by your own policies; inform before use.
Watch
The employer’s duty of care covers monitoring. The data protection act was overhauled in 2023, with the duty to inform at its centre.
What starts it
Working-time and policy changes that alter the contract need each employee’s agreement, or a notice of modification with the contractual notice period. The representation is consulted on health and safety and working-time matters covered by the Labour Act.
The clock
Changes imposed by notice take effect after the notice period, typically one to three months.
Watch
A notice of modification handled badly is an abusive dismissal.
Sources for Switzerland, reviewed 2 October 2026

United Kingdom

No works councils by default. You consult a recognised trade union where there is one, otherwise representatives elected for the process in hand. Employees of a 50-plus employer can require a standing information and consultation arrangement (2% of staff, at least 15 people) under the 2004 regulations.

What starts it
Proposing 20 or more redundancies at one establishment within 90 days triggers collective consultation with the union or elected representatives, and advance notification on form HR1 to the Insolvency Service (online only since 1 December 2025).
The clock
Consultation must start in good time and at least 30 days before the first dismissal takes effect, 45 days for 100 or more. Individual consultation runs alongside.
Watch
The Employment Rights Act 2025 doubles the maximum protective award to 180 days’ pay per employee (from April 2026) and adds a second, company-wide trigger to be set by regulations. Under 20 at a site is no longer a safe harbour by itself.
What starts it
A transfer of a business, or a service provision change (outsourcing, insourcing, re-tendering), means both employers inform, and consult on any measures, with the union or elected representatives. Employers with fewer than 50 staff, or transfers of fewer than 10 employees, may consult staff directly where there are no representatives.
The clock
No fixed period: long enough before the transfer for consultation to be meaningful. Allow four to six weeks for electing representatives and consulting. Employee liability information goes across 28 days ahead.
Watch
Up to 13 weeks’ uncapped pay per employee for a failure. Changing terms because of the transfer is void.
What starts it
No statutory consultation duty on a new system as such, but the ICO expects a data protection impact assessment and transparency for monitoring, and a union agreement or a standing information and consultation arrangement may require consultation on decisions likely to lead to substantial changes in work organisation.
The clock
Driven by your own agreements and the DPIA; typically a few weeks of consultation with a recognised union.
Watch
The Employment Rights Act 2025 widens union recognition and workplace access. Many UK employers are moving from informing to consulting on AI tools before they are asked to.
What starts it
Changes to contractual terms (pay, hours, location) need agreement, and the Employment Rights Act 2025 restricts dismissing employees for refusing a change to core terms (fire and rehire), so check which provisions are in force when you plan. A standing arrangement or union agreement adds consultation.
The clock
Consultation and agreement before the change. Where 20 or more dismissals might follow refusals, the collective redundancy rules apply too.
Watch
The code of practice on dismissal and re-engagement can raise awards by a quarter.
Sources for United Kingdom, reviewed 2 October 2026

Your European Works Council

An EWC can be requested where a group has at least 1,000 employees in the EEA and at least 150 in each of two countries. Directive (EU) 2025/2450, the recast, has been in force since 31 December 2025 and must be transposed by 1 January 2028. More decisions count as transnational, including matters that concern one country but can reasonably be expected to affect workers in others; the EWC’s opinion must get a reasoned response in writing; experts and training are funded by the employer; and penalties must be dissuasive. Pre-1996 “Article 14” agreements lose their exemption from 2 January 2028, and the remaining provisions apply from 2 January 2029.

You have one
Inform and consult the EWC in time for its opinion to matter to the decision, and link it to the national processes rather than running it afterwards. Your EWC agreement sets the detail: what it calls transnational, how long the EWC has, and what the reasoned response must contain.
You do not have one
If the thresholds apply to you, employees or their representatives can request an EWC at any time, and a request in the middle of a restructuring is common. If you rely on a pre-1996 agreement instead, its exemption ends on 2 January 2028.
Not sure
Groups of this size usually have an EWC, or a request pending. Check with the group’s HR or legal function before planning any change that touches more than one country.
Sources for the EWC, reviewed 2 October 2026

Orientation, not legal advice. The thresholds and periods are the statutory ones; your agreements, bodies and earlier commitments decide what applies to you, and a lawyer in each country confirms it.

The questions only your landscape can answer.

The law sets the floor. What applies to you is in your agreements, your bodies and your history. Landscape holds those answers; Change Proposals runs the sequence; the record is produced from it, not reconstructed afterwards.

See how Landscape answers them

  • Which bodies actually exist at each site, and who sits on them today?

    The law says what can exist. Your landscape says what does: a works council at one plant, a union delegation at another, nothing at the third.

  • What do your own agreements add?

    Works agreements, company and sector agreements, and framework agreements on IT or restructuring often add notice periods, information packs or consent rights beyond the statute.

  • What does your EWC agreement call transnational, and what timetable does it set?

    The directive sets the floor. The agreement sets the clock, the papers and who speaks for management.

  • Which earlier commitments still bind you?

    A social plan from the last restructuring, a promise made in a previous consultation, an opinion still waiting for its reasoned response.

  • How do the numbers add up the way each country counts them?

    Establishment or region, 30, 60, 90 or 120 days, which departures count: the same programme crosses a threshold in one country and not in the next.

  • What has to happen in sequence, and who confirms the record is complete?

    Which body is informed first, which consultation must close before a decision is announced, and where the dated evidence of all of it lives.

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