Your ER knowledge already exists. Finding it at the right moment is the hard part.

Welcome to the first issue of The Graylark ER Review: once a month, one idea about ER technology, three developments worth knowing about, and one question to ask of your own systems.

Picture a fairly ordinary week. A restructuring is announced in one of your countries, and someone asks whether the company took advice on something similar a few years ago. It probably did.

But the person who asked for it has moved roles, the email thread is buried somewhere, and nobody is quite sure whether the advice still holds.

That isn’t really a knowledge problem. The organisation has already paid for the advice, and it’s sitting somewhere. The problem is finding it, and finding it at the right moment.

Search helps, but only if someone knows there’s something to look for. In a multinational ER function, where advice, agreements and consultation history build up over years, across countries and issues, that’s a big assumption.

Our view is that the systems ER teams rely on should do more of the remembering. That starts with storing information alongside the context that makes it useful later: where it applies, what it relates to and when it was last reviewed. It then means connecting that knowledge to what is changing in the organisation, so the right information comes back into view when it’s needed.

It sounds simple. In practice, most of the work is in how the information is structured, not in the search box.

Three things on our radar

1. Pay transparency: the deadline has passed, the patchwork hasn’t

The Pay Transparency Directive was due in national law by 7 June. By late September, five Member States had fully transposed it: Italy, Lithuania, Malta, Slovakia and, since June, Greece. Most of the rest have published drafts, and the Netherlands, Denmark and the Czech Republic are among those aiming for 1 January 2027.

For a multinational, the practical answer is one EU-wide baseline, adjusted as each national law lands, not a separate project in every country.

Lockton: EU Pay Transparency Directive implementation status, September 2026

2. AI Act: the duty to inform worker representatives has moved too

The AI Omnibus, in force since 27 July, moved the high-risk obligations for AI used in employment and worker management from 2 August 2026 to 2 December 2027, and with them the employer’s duty to inform workers and their representatives. Most transparency obligations kept their August 2026 date.

That buys time, not an exemption. Start an inventory of the AI already in your HR and ER workflows, so you know what your works councils will need to hear about.

White & Case: EU AI Omnibus enters into force, amending the AI Act

3. European Works Councils: is your agreement ready for the new rules?

Member States have until 1 January 2028 to transpose the revised EWC Directive, and its main provisions apply from 2029: consultation in good time, confidentiality that management must justify, and sanctions that are genuinely dissuasive.

It also ends the exemption for agreements signed before September 1996. If yours is one of them, plan how it will be brought into line. If not, it is still worth checking how your agreement handles timing and confidentiality before 2029.

Morgan Lewis: EU Strengthens European Works Councils Framework

The ER Tech Question

If the person who knows where everything is left tomorrow, how much of your ER knowledge would leave with them?

Most organisations have someone who knows where to look. They remember that a similar issue came up three years ago, which folder holds the agreement, who gave the legal advice and which version of a document was finally signed off.

That experience is valuable. The technology question is whether the information behind it is also available to everyone who might need it later, not only to the person who remembers.

Worth a read

Roche’s Secret To 24-Hour Works Council Alignment: Trust

Keith Ferrazzi, Forbes, August 2026

Roche’s Chief People Officer, Cris Wilbur, describes sharing information with works council representatives earlier, and creating what she calls “parity” in what both sides know. She says some works council processes have been completed in as little as 24 hours.

What caught our attention wasn’t just the speed. It was what had to be in place first: information shared early enough for people to understand it, question it and engage with it properly.

What we are learning at Graylark

Building Graylark, we keep coming back to one lesson: searchable doesn’t always mean useful.

Legal advice is a good example. You can store every piece of advice an organisation has ever received and still miss the one that matters, because nobody thinks to search for it.

That’s why we’ve been working on how legal advice is organised in Graylark, including its jurisdiction and review information, and on how GrAI Insights can bring relevant advice back into view when a change in the organisation makes it useful.

The same principle runs through the rest of the platform: keep the context, not just the document.

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That’s it for the first edition of The Graylark ER Review.

If anything here connects with a challenge you’re working through, get in touch. We’d be interested to hear how you’re approaching it.

If one of these changes is heading your way, our free Consultation Readiness Check sets out what the law asks for in 15 European countries and for your European Works Council. That is the floor. Graylark brings together your own works councils, agreements, past changes and legal advice, so the insight fits your organisation, not just the statute.

The Graylark Team