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IR Notes 269 – 11 March 2026
www.irshare.eu
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A question for…
Yohann Dauvet, Labour Relations Manager at Albéa Tubes Beautycare
Your company has signed an
agreement on social dialogue linked to the use of artificial
intelligence systems (see IR
Notes 268). Why did your
management think it would be useful to go down this
road? The
idea of negotiating a social dialogue agreement on this topic was
first suggested by the firm of consultants that provides support to
the central works council (CSE-C), before being fully adopted by the
trade unions. From management’s point of view, this initiative forms
part of a desire to effect continuous improvements in social
dialogue, such as by establishing transparency and holding
discussions on an emerging topic that is likely to give rise to
fears. It’s true that the employer’s legal obligations are still
vague, and recent case law may give rise to a certain legal
insecurity. By choosing to negotiate an agreement, we’ve imposed a
strict framework on ourselves with regard to information and
consultation, thereby encouraging ongoing social dialogue. Yet this
approach has also enabled us to avoid any additional constraints.
For example, in the event of a minor update of an AI agent or
preliminary testing prior to possible deployment, our agreement
simply provides for workforce representatives to be notified,
without triggering a formal consultation. On the other hand, for
projects with a high impact, we’ve established a rigorous
information and consultation procedure. This agreement means we can
now present documented and concrete plans to the works council,
rather than fearing we could be in breach of our legal obligations
in the area of information and consultation. Without this framework,
bringing in employee representatives early on, at the design or
testing phase, could have exposed the company to criticism that not
enough information had been disclosed, or even to legal action taken
by the works council. In the end, this ongoing social dialogue
offers us legal security, while at the same time enabling us to
focus on the development of AI systems. This arrangement means the
works council is consulted at the appropriate time, i.e. where these
systems are likely to have a genuine impact on working
conditions.
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Agenda
18 March Brussels Tripartite
Social Summit
18 March Brussels The
European Commission is due to adopt a legislative proposal for the
purpose of establishing the 28th regime (see agenda).
20 March Bordeaux Symposium
entitled La démocratie au travail dans la transition
environnementale [‘Democracy at work in the environmental
transition’], organised by the Institut du travail de Bordeaux (registration)
24 March Online Webinar
organised by the European employers’ federations EFSI and EFFE, with the
support of the European Commission, on the topic of “Delivering Quality
Jobs in Europe: The Expanding Role of Collective Bargaining” across the
Personal and Household Services (PHS) sector in Europe, with an
intervention by Maria Sedlakova, a research officer at Eurofound (registration).
26 March
Online
Webinar organised by Eurofound and EIGE on “Launching
the EU-wide guidelines on gender-neutral job evaluation and
classification”.
21 April
Brussels
Eurofound is organising an event to unveil the latest results of its
European survey on working conditions: Working
in the age of AI – How are working conditions changing across
Europe?
29 June Luxembourg Employment
and Social Affairs Council
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Lead
story
Pay
transparency: a patchwork of harmonisation
Directive 2023/970, adopted
on 10 May 2023, is intended to boost equal pay and pay transparency in all EU Member
States (see IR
Notes 205). It sets a deadline of 7 June 2026 for countries to transpose
this directive into their domestic law. However, a Eurofound study
published in late October 2025 already showed that progress in its transposition in
all Member States was still limited. Thus far, implementation of the directive is
proving to be unequal and complex, creating a mosaic of rules, which in turn is
making it difficult for companies and workforce representatives to harmonise their
practices. First of all, the directive’s transposition is significantly behind
schedule in many countries. Despite a period of three years being allowed for
transposition – rather than the two years usually allowed for social directives –,
several Member States have not yet finalised their legislation. In France, for
example, the draft law is still being discussed with the social partners, and looks
set to miss the 7 June 2026 deadline. A partial implementation is scheduled only in
2027. In Denmark, the directive’s application is not expected before 1 January 2027.
So far, only the Wallonia-Brussels federation in Belgium has completed the
transposition process. These delays mean an equivalent delay in implementing the
employers’ obligation to provide information on pay scales and to publish reports on
pay gaps. Next, Member States are interpreting and applying the directive in very
different ways. The leeway left by the European text permits adaptations, or even
“over-transpositions”, i.e. measures that go beyond the minimum requirements. For
example, in France, the draft law stipulates that job applicants must be notified of
an initial pay range, whereas in Italy, they must be told the exact amount of the
proposed wage. Another point of divergence concerns the report on gender pay gaps,
which must include variable and supplementary components. The directive requires
companies with 250 or more employees to publish an annual report, while those with
between 150 and 249 employees must publish a report once every three years.
Companies with between 100 and 149 employees will have eight years to produce their
first report, and they will then have to update it once every three years. Yet some
countries are imposing a stricter version of these obligations: in Italy, all of the
employers concerned will have to produce this report on an annual basis, while in
Denmark, the threshold is reduced to 100 employees. France, for its part, is
maintaining its current threshold of 50 employees, linked to its existing “Equality
Index”. Lastly, the methods used to assess pay gaps also vary from one country to
another. In Italy, this analysis is based primarily on collective agreement
categories, even though a company’s internal classification may be taken into
account. In Denmark, employers will have to use the country’s official DISCO
nomenclature, which classifies occupations into 372 occupational subgroups. These
differences in methodology complicate the task of making data comparisons between
countries and make the work of workforce representatives harder at European level.
When all is said and done, while the objective of pay transparency is a shared one,
its implementation continues to be fragmented. Workforce representatives will have a
key role to play if they are to ensure that the principles of equality and
transparency are effectively applied, despite the disparities between Member States.
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1. European
Union
Legislation
The “Omnibus I” directive has completed its
journey : One year after the European Commission published
its first “Omnibus” proposal, on 26 February 2025, the text – which amends
the corporate sustainability reporting (CSRD) and due diligence directives –
was published in the OJEU the day after the Council granted its
final approval. Companies’ management and employee representatives will now have an
official version of the text in their own language – a development that will
facilitate the directive’s application, by removing the need to consult the multiple
compromise texts that preceded its final adoption. The directive, which will come
into force on 19 March, has significantly increased the thresholds at which the CSRD
and CS3D become applicable. Previously, the CSRD directive applied to companies with
250 or more employees, but it now applies to those with over 1,000 employees and an
annual turnover in excess of 450 million euros (rather than 40 million). For its
part, the due diligence directive now applies only to companies with more than 5,000
employees (rather than 1,000) and a net turnover in excess of 1.5 billion euros
(rather than 450 million euros). The revision also introduces a number of changes
offering businesses greater flexibility. As far as due diligence is concerned, the
text allows a company that has identified several equivalent risks (i.e. having the
same level of seriousness or probability) not to tackle them all at once: instead,
it can choose to start with the ones linked to its direct business partners, i.e.
suppliers or subcontractors with which it has a direct contractual relationship. The
CS3D obligation requiring businesses to adopt a transition plan for climate change
mitigation has been abolished. The directive postpones the deadline for transposing
the CS3D into domestic law by a further year, fixing this at 26 July 2028. Andreas
Rasche, Professor and Associate Dean at Copenhagen Business School, comments: “While
politicians can simplify laws, they cannot simplify the massive environmental and
social problems that European businesses must address”. Moreover, while the legal
obligations have disappeared, the requirements imposed by banks, investors and
business partners remain in place, and many businesses will still have to publish
very detailed reports and demonstrate their due diligence credentials, if they are
to secure financing on favourable terms.
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European Globalisation Adjustment Fund :
On 25 February, the Council reached a provisional
agreement on the proposal for a regulation to expand the scope of
application of the European Globalisation Adjustment Fund for displaced workers
(EGF). Once it has been formally approved by the Council and Parliament, the text
will be published in the OJEU. The proposal, which was presented by the
European Commission on 1 April 2025 (see IR Notes
249), seeks to expand the scope of EGF aid, so that it will apply not only
to dismissed workers but also “to workers affected by imminent job displacement in
enterprises undergoing restructuring”. The EGF’s intervention should enable them to
“acquire the skills they need to transfer either into a different role with their
current employer or to a different employer”. The workers concerned are those “whose
employment contract or relationship is expected to be ended by redundancy according
to the written communication from the employer to the workers’ representatives
informing them, during the course of the consultations with them, inter alia, of the
number and categories of workers to be made redundant in accordance with Article
2(3) of Directive 98/59/EC”. The employees in question must be the subject of a
projected collective redundancy of at least 200 workers in an enterprise undergoing
restructuring, though exceptions to this threshold are provided for. The application
for intervention is to be formulated by the company and then referred to the
Commission by the Member State concerned, within tight deadlines. Furthermore, with
regard to the totality of applications for aid (concerning employees who either have
already been, or are at risk of being, made redundant), EGF funding in favour of any
given enterprise shall not exceed 4 million euros per Member State for any given
financial year. The text emphasises that “this provision seeks to limit the risk
that any individual enterprise depletes the funding resources, and to ensure that
funding will be available for restructurings across different Member States” – a
change that will rule out aid on the scale of the €17.7 million spent on supporting
1580 former Air France employees in 2022 and the €12.8 million on 2,500 former BenQ
employees after the company was declared bankrupt. Since 2007, the EGF has
intervened in 186 cases, and spent 727 million euros on helping more than 181,167
workers in 20 Member States. According to the latest data for 2023-2024 (report
and annex),
81% of redundant employees found a new job within 18 months after EGF funding was
granted (see EGF
page on the Commission’s website, a list
of EGF funding applications granted and press releases issued by the Council
and the Commission).
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Social
update
- Restructuring : On 2 March,
the European Commission proposed mobilising 2 million euros from the European
Globalisation Adjustment Fund to support 507 workers who were dismissed in April
2025, following the bankruptcy of the steelmaker Liberty Steel Belgium (see press
release).
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- Employment and Social Affairs Council :
On 9 March, among other steps taken, the Employment
Ministers of the Twenty-Seven adopted a recommendation on human capital, which
will provide guidance to Member States on tackling labour and skills shortages
across the EU. The Ministers also exchanged views on the use of AI to strengthen
quality jobs and workers’ rights (see Council press
release).
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Sectoral
social dialogue
Hairdressing : On 2 February,
the European social partners in the hairdressing sector (UNI Europa and Coiffeur
EU), issued a joint declaration calling on, among others, the European Commission
and Member States to curb bogus chair renting in hairdressing salons, a practice
that “poses a serious threat to sustainability, professionalism, and fair working
conditions in the sector”, according to the signatories (see UNI Europa press
release).
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2. Member
States
Belgium
A “right to make a new start” :
As of 1 March, employees who have more than ten years’ career
experience can exercise their “right to make a new start”, a benefit also known as
the “trampoline bonus”, which was established via the programme
law of 18 July 2025. This mechanism entitles workers to receive unemployment
benefits for a six-month period after they have resigned from their job, of their
own free will. The aim is to make it easier for employees who can demonstrate, via
an application submitted in advance and checked by the public employment department
(ONEM), that they have a clearly structured plan
to retrain for a different occupation. This period can be extended for a further six
months if the employee is training for an occupation experiencing a labour shortage.
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Spain
Transgender workers : On 26
February, the government and the two trade-union confederations CCOO and UGT signed
a Memorandum
of understanding in support of transgender persons in the workplace. This
agreement affirms the undertaking given by Article 15.1 of Law 4/2023 of 28 February
2023 for genuine and effective equality for transgender persons and for
guaranteeing the rights of LGTBI persons, affirming the integration of trans people
into the employment market. The memorandum establishes a set of recommendations on
how to recognise and show respect for the gender manifested by the worker (e.g.
acknowledging legally recognised pronouns). This memorandum demonstrates the
commitment on the part of the Spanish Ministry of Labour and the social partners to
create a working environment that is more respectful of diversity (see press
releases issued by the government,
the CCOO
and the UGT).
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Greece
Strengthening collective bargaining :
The law
on strengthening collective labour agreements has entered into force.
Following a public consultation in February (see IR Notes
266), it was approved by Parliament with a number of minor amendments. Among
other things, this law seeks to boost the number of employees covered by collective
labour agreements, to promote collective bargaining and to improve the framework
governing the conclusion, implementation and extension of collective labour
agreements. It also seeks to fully protect employees after a collective agreement
has expired, and to speed up and rationalise the procedures for resolving industrial
disputes.
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Italy
AI Observatory publishes its first report on
employment : In 2025, Italy took the pioneering step of
launching its AI regulations, to implement the European rules (see IR Notes
259), and a national observatory to monitor AI’s impact on employment. The
Observatory recently published its first report,
on 19 February. This reveals geographical disparities in the use of AI and
highlights an imbalance between skills and training, and in particular the gap
between supply and demand when it comes to STEM professionals. It also shows that
businesses have been slow to invest in digitalisation processes (see press
release).
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Malta
Climate changes : On 5
March, the Malta Council for Economic and Social Development (MCESD
– a tripartite consultative body for social dialogue) – examined the issues of
disaster preparedness and emergency coordination, at the request of the Malta Hotels
and Restaurants Association (MHRA). This meeting, which focused on climate change,
highlighted growing concerns linked to its effects in a country where tourism is an
important industry. The discussions covered measures firstly to raise awareness of
actions that need to be taken and secondly to improve coordination between the
social partners, public bodies and the government (see press
release).
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Netherlands
Temporary work : Since the start
of the year, temporary workers have been entitled to receive remuneration equivalent
to that of a permanent employee in the same job (see press
release). However, this measure has not led to any significant improvement
in working conditions. Temporary-work agencies are finding it hard to precisely
define these equivalent pay levels, especially when it comes to the inclusion of
housing deductions. In addition, organisations representing temporary-work agencies
have signed an agreement to apply this rule with the trade union LBV, and not with one of the three main trade
unions, which raises questions about representativeness.
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Poland
Online employment contracts : On
24 February, the Council of Ministers adopted a plan to establish a centralised
digital system for managing contracts of employment. This platform will enable
employers to conclude, amend or terminate contracts, and to use standardised
template documents (see press
release). It will be freely accessible to everyone, and will also cover
other types of agreements, including those related to training. This initiative
should also simplify the administrative steps involved, especially in terms of
recruiting foreign workers.
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3.
Companies
Restructuring
A major merger in aerospace : On
22 October 2025, the Airbus,
Leonardo and Thales groups announced the
signing of a memorandum of understanding aimed at grouping together their space
activities within a new entity, to be known as Bromo. The stated aim is to “create
a leading European player in space” (see
press release). The new company will employ around 25,000 people across
several European countries. With an estimated annual turnover of 6.5 billion euros
(pro-forma, end of 2024) and an orderbook covering more than three years of
projected sales, Bromo’s critical size will enable it to innovate and compete at
global level with rivals such as the Starlink network. Trade-union officials
representing employees of all three groups – based in Belgium, France, Germany,
Italy, Poland, Spain and the United Kingdom – met under the auspices of IndustriAll
Europe on 1 December 2025. Their aim was to work out a joint approach to dealing
with this merger. Among other things, they called for jobs and production sites to
be preserved, for working conditions to be maintained (by retaining collective
agreements for transferred employees), and for workforce representatives’ rights to
information and consultation to be respected at every stage of the project and at
all levels (see press release). In a joint
letter to the managements of Airbus, Thales and Leonardo, 14 trade unions
from several European countries pooled their demands. They call for concrete
guarantees within the framework of the merger, including: 1/ the
negotiation, as soon as Bromo is created, of a new European Works Council including
representatives of all the countries concerned, and at minimum, incorporating the
best social practices and expertise of the existing EWC agreements in place at
Airbus, Thales and Alenia Space; 2/ a guarantee of employee
representation on the board of directors of the Bromo holding company.
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Relocation to India : The German
chemical group BASF has
announced the creation of a new shared services centre in India. This site will
centralise the company’s financial and personnel management services, which are
currently based in Europe. Employee representatives are expressing fears about the
consequences of this decision, including that thousands of jobs will be moved
offshore, especially from the shared services centre in Berlin (see IG BCE and IndustriAll Europe
press releases).
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