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: Spain overhauls employer information obligations under new transparency rules
Royal Decree 723/2026, published in Spain’s Official State Gazette on 15 September and in force since 5 October 2026, replaces the 1998 employer information framework and partially transposes the EU Directive on Transparent and Predictable Working Conditions (2019/1152). The decree significantly expands what Spanish employers must tell their employees about the terms and conditions of their employment.
The new obligations go well beyond the basics. Employers must now disclose detailed information on pay (base salary, supplements, variable components, payment method and frequency), working time (schedules, overtime rules, shift systems, holiday entitlement and advance notice for roster changes) and broader conditions (probationary periods, training entitlements, termination procedures, applicable collective agreements, social security and pension arrangements). The decree also requires disclosure of the company’s equality plan, harassment protocol and, where they exist, work-life balance policies and LGBTI workplace measures.
One provision stands out: where algorithmic or automated systems support decisions on work allocation, scheduling, pay, career progression, workplace assignment or termination, employers must disclose the existence and operation of those systems. This aligns Spain’s employment transparency rules with the broader EU push towards AI accountability in the workplace. For international assignments lasting more than four consecutive weeks, additional disclosures cover the host country, duration, pay currency, allowances, expenses and repatriation conditions, with further requirements for postings within the EU and EEA.
Information must be provided in writing before employment begins. Changes must be communicated by the date they take effect. Existing employees can request the information and must receive it within 30 working days.
What to do: Spanish employers should review all contract templates, onboarding documents and written particulars against the new requirements now. Pay particular attention to the algorithmic disclosure obligation if your organisation uses any form of automated decision-making in scheduling, performance assessment or workforce management. The obligations apply immediately, regardless of whether the Ministry of Labour has published its official template document.
Also developing
United Kingdom: The illegal working civil penalty regime expanded significantly on 1 October 2026 under section 48 of the Border Security, Asylum and Immigration Act 2025. Right-to-work liability now extends beyond direct employers to cover businesses with subcontracting chains, operators of online matching platforms and arrangements involving substitution clauses. Multiple entities in the same chain can be held liable for a single worker. The maximum penalty remains £60,000 per illegal worker. A statutory excuse now depends on specific contractual terms being in place before work begins, meaning existing supply chain contracts may need renegotiation. The Home Office published draft codes of practice and an updated employer guide during summer 2026, with final versions expected imminently. What to do: UK employers should map their exposure across subcontractors, agency arrangements, platform workers and any substitution clauses. Review supply chain contracts to ensure right-to-work obligations flow down and that the terms required for a statutory excuse are in place.
Germany: The Federal Labour Court (BAG) has ruled that an ordinary termination notice is invalid if it arrives without proof of the signatory’s authority to dismiss. In a case decided on 7 May 2026 (Ref. 2 AZR 130/25), a managing director’s employment was terminated by a letter signed by two of three supervisory board members with no evidence of their authority attached. The managing director rejected the notice four days later, which the court held was prompt under an analogous application of Section 174 of the German Civil Code. A separate extraordinary termination, sent electronically as part of a court pleading, was also struck down for failing the written-form requirement. Although the case involved a managing director, the reasoning applies equally to standard employee dismissals. What to do: German employers should ensure that any termination notice is accompanied by original proof of the signatory’s authority to dismiss. Where joint representation rules apply, document and disclose the authorisation chain before serving notice.
EU: The European Parliament’s Committee on Employment and Social Affairs has voted to advance the sixth revision of the Carcinogens, Mutagens and Reprotoxic Substances Directive. The revision adds welding fumes to the list of covered processes and introduces new occupational exposure limits for cobalt and its inorganic compounds (relevant to battery production), polycyclic aromatic hydrocarbons (steel, iron and aluminium production), 1,4-dioxane (chemical and textile industries) and isoprene (chemical and rubber production). Employers will also be required to provide training for workers exposed to hazardous medicinal products and to incorporate a gender perspective in future exposure assessments. The directive must still pass a plenary vote and Council approval before entering force. What to do: Employers in manufacturing, chemicals, battery production and metalwork sectors should begin reviewing exposure monitoring and PPE arrangements for the named substances, even though transposition timelines aren’t yet confirmed.
Sweden: The government has confirmed the 2027 price base amount (prisbasbelopp) at SEK 59,600, an increase of SEK 400, with the elevated price base amount set at SEK 60,900. These figures underpin the calculation of social insurance benefits, sanction fees under employment legislation and occupational pension thresholds across collective agreements. Any employer whose pension or benefit calculations reference the base amount will need to update payroll parameters from 1 January 2027. What to do: Swedish employers should update payroll systems and pension administration for the new base amounts effective 1 January 2027. Check whether any collective agreement thresholds or benefit caps are linked to the price base amount and adjust accordingly.
On the radar
UK, 30 October (previously covered): the strengthened third-party harassment duty, trade union workplace access rights (employers with 20 or more staff, fines up to £500,000 for non-compliance) and extended protections for industrial action all take effect. The trade union right-to-join notice duty has been postponed to January 2027. The government has also confirmed a new right to unpaid bereavement leave from April 2027.
EU Platform Workers Directive (previously covered): the 2 December 2026 transposition deadline approaches with no member state fully transposed. Germany is actively drafting; the Netherlands has acknowledged it will miss the deadline.
Belgium (previously covered): the Private Investigations Act compliance deadline of 16 December 2026 is now two months away. Internal HR investigation procedures must meet the Act’s requirements on written consent, disclosure and investigation registers.
Sources
- Squire Patton Boggs: Spain introduces new employer information obligations, in force from 5 October 2026
- Littler: October 2026 right to work changes in the UK, liability extends to subcontractors and supply chains
- Macfarlanes: right to work checks, extended liability for organisations from 1 October 2026
- Ogletree Deakins: no proof of authority, no termination, Germany’s Federal Labor Court rules
- EU-OSHA: EU directive revision to better protect workers from hazardous substances
- DLA Piper: Nordic Employment Law Bulletin, October 2026
- Hogan Lovells: employment in the news, October 2026
- Simmons and Simmons: employment law alert UK, October 2026
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.
