Trade union concerns about the proposed e-Declaration for posting

On 13 November 2024, the European Commission launched its proposal for a regulation on a public interface for the declaration of posting of workers. This so-called e-Declaration aims to put in place a common digital multilingual declaration form for interested Member States to implement on a voluntary basis, with the aim to reduce administrative burdens for posting employers.

The ETUC has expressed strong concerns in a letter to the Commission about the purpose and process leading up to this proposal, which is part of the Commission’s 25% burden reduction target for businesses. As is illustrated also by the Commission’s preparatory documents, attention is almost exclusively given to economic aspects, whereas very little consideration has been given to the risks or potential social costs this proposal might entail as a result of reduced reporting on posting.

The ETUC has recalled that the aim of the information collected by posting declarations is to support labour inspectorates in the monitoring and enforcement of the posting rules. By setting numerical targets for cutting business reporting requirements without first considering what information inspectorates need to effectively protect workers’ rights, the e-Declaration risk becoming a missed opportunity for improved enforcement

These concerns are elaborated in more detail in the ETUC press release.