A weekly briefing on European HR, labour law and compliance developments for SME HR teams across the EU, UK, Switzerland and the Nordics.
Top story: Commission launches Fair Labour Mobility package to digitise cross-border worker rights
On 15 September 2026, the European Commission adopted a Fair Labour Mobility package that aims to make social security rights, professional qualifications and skills genuinely portable across EU borders. The package has three pillars, and all three carry practical implications for HR teams managing cross-border employees or posted workers.
The centrepiece is the European Social Security Pass (ESSPASS). Once the ESSPASS Regulation enters into force, the portable document A1, which employers must obtain for posted workers, will be available as a fully digital document within one year. The European Health Insurance Card and other social security documents will follow within three years, all accessible through the EU Digital Identity Wallet. The Commission estimates that digitalisation could save businesses up to EUR 64 million over 12 years through faster cross-border verification, with comparable savings for healthcare providers and labour inspectors.
A second pillar, the Skills Portability Initiative, introduces a framework for qualifications to be issued, compared, verified and recognised more easily across member states. Non-EU qualifications will benefit from a simpler recognition process within two years of adoption. For regulated professions, recognition will be streamlined within three. A third regulation strengthens the European Labour Authority (ELA), giving it sharper tools for risk-based inspections, a new mandate to tackle abuses against third-country nationals working in the EU and a simplified mediation procedure for cross-border disputes between member states.
What to do: These are proposals, not law yet, and will need to pass the European Parliament and Council. But the direction is clear. European SMEs employing cross-border workers or posting staff to other member states should start familiarising themselves with the A1 process if they have not already, because the digital version will require the same underlying documentation. HR teams handling qualification recognition for new hires from other EU countries should watch for the Skills Portability rules, which could simplify what is currently a time-consuming process.
Also developing
EU: The AI Act Omnibus regulation entered into force on 27 July 2026, formally pushing the compliance deadline for high-risk AI systems in employment from 2 August 2026 to 2 December 2027. AI systems used for recruitment, candidate screening, performance evaluation, promotion decisions, task allocation and employee monitoring are all classified as high-risk under the Act. The delay gives employers 16 additional months to prepare, but Article 50 transparency obligations remain on schedule: employers deploying AI that generates or manipulates content, or that interacts directly with employees or candidates, must already disclose this. What to do: Do not treat the delay as a reason to ignore the AI Act. Map every AI tool your HR team uses today, from CV screening to chatbot-based onboarding, against the high-risk categories in Annex III. Start documenting how each tool works, what data it processes and how a human reviews its outputs. The transparency obligations are already live.
Germany: The coalition’s “Programme for Economic Recovery and Employment”, announced on 2 July 2026, is entering the legislative drafting phase this autumn. The package includes significant employment law changes: fixed-term contracts without objective justification would be permitted for up to 48 months (currently 24) with up to six extensions, applicable to employees hired before 31 December 2030. For high earners above approximately EUR 177,450 gross per year, a new termination route would allow employers to dissolve the employment relationship with a court-determined severance payment, without needing standard dismissal grounds. Separately, the obligation to submit a medical certificate from the first day of illness is set to replace the current three-day rule, and telephone-issued certificates would be abolished. No formal bill has been tabled yet, but the political agreement between CDU/CSU and SPD means the reforms are likely to reach the Bundestag this autumn. What to do: German employers should not wait for the final text. Review fixed-term contract usage to understand how the extended maximum could support workforce planning. Assess which employees fall above the high-earner threshold for the new termination route. Update absence management policies to prepare for day-one certification.
Netherlands: The FNV, the country’s largest trade union, published its collective bargaining demands on 15 September 2026 ahead of Budget Day, calling for a 5.5% increase in basic pay supplemented by a flat EUR 80 per month to give a larger relative boost to lower earners. The CNV union is pushing for increases between 3% and 5.5%. Employers’ organisations have responded by calling for negotiations to focus less on wages and more on broader working conditions. Several recent agreements provide context: the Dutch universities’ CBA delivered a 3.1% rise plus EUR 50 per month from 1 July 2026 with a one-off payment of up to EUR 1,534, while research institutes agreed a 5% increase from 1 September with a further 1% from January 2027. What to do: Dutch employers approaching CBA renewals should budget for pay increases in the 3% to 5.5% range and consider whether a flat-euro component alongside the percentage would help with retention of lower-paid staff. Review your compensation benchmarks against recently concluded agreements in comparable sectors.
Sweden: Stricter labour immigration rules took effect on 1 June 2026, raising the minimum salary threshold for work permits from 80% to 90% of the Swedish median salary (currently SEK 29,680 per month). Around 20 shortage occupations are exempt and subject to a lower threshold of 75% of the median. Employer penalties have doubled: the fee per foreign national is now SEK 118,400, rising to SEK 236,800 for violations lasting more than three months. The Swedish Migration Agency can now reject applications outright where the employer has a history of certain criminal sanctions. Health insurance covering medical care and repatriation is required for stays of up to one year. Transitional rules apply to extensions of permits granted before June, provided the renewal application is filed by 1 December 2026. What to do: Swedish employers sponsoring work permits should verify that salary offers meet the new 90% threshold. Check whether any roles qualify for the shortage occupation exemption. For existing permit holders, note the 1 December 2026 deadline for filing extension applications under the old rules.
On the radar
UK Acas Code consultation (previously covered): the consultation on the revised Code of Practice on disciplinary and grievance procedures closes tomorrow, 23 September 2026. The draft proposes a shift towards informal resolution, extends the scope from “employees” to “workers” and introduces new sections on mediation, reasonable adjustments and manager training. Formal disciplinary processes cost UK employers an estimated GBP 2.36 billion a year.
UK Employment Rights Act, October 2026 (previously covered): tribunal time limits double from three to six months on 1 October. The trade union rights statement, workplace access, third-party harassment duty and union equality representatives’ time-off rights all land on 30 October. The fire and rehire ban has been pushed to January 2027.
EU Platform Workers Directive (previously covered): member states must transpose by 2 December 2026. Sweden has proposed a standalone Platform Work Act targeting the same date. The Netherlands has acknowledged it will miss the deadline.
EU Pay Transparency Directive (previously covered): 22 of 27 member states are still working on transposition. No material change from last week’s edition.
Sources
- European Commission: Fair Labour Mobility package announcement, 15 September 2026
- European Commission: Fair Labour Mobility package overview
- Remote Work Europe: EU proposes digital A1 certificate and European Social Security Pass
- Gibson Dunn: EU AI Act Omnibus agreement, postponed high-risk deadlines
- Ogletree Deakins: EU delays rules for AI use in employment decisions
- CMS: Germany’s reform package for economic recovery and employment
- DLA Piper: German reform package, employment law implications
- NL Times: FNV pushing for 5.5% wage increases in collective labour agreements
- DutchNews: FNV union demands 5.5% pay rises
- Swedish Migration Agency: new rules for labour immigration from 1 June 2026
- EY Sweden: new rules for labour immigration from June 2026
- Acas: consultation on draft Code of Practice on disciplinary and grievance procedures
Europe HR Compliance Pulse Weekly is an informational summary of publicly reported legal and regulatory developments. It is not legal advice. Always confirm obligations for your specific situation and market with a qualified adviser.
