The Revised European Works Council Directive: what, when, and why employers should prepare

Littler International 18/03/2026

The revised European Works Council (EWC) Directive was published on 11 December 2025, following its adoption by the European Parliament earlier that year. It introduces substantial changes to the legal framework governing transnational information and consultation in multinational undertakings and groups of undertakings operating within the European Economic Area.

The Directive’s objectives are clear: strengthening the effectiveness of EWCs and addressing long-standing enforcement gaps. Its practical impact for employers will accordingly be significant. Member States must transpose the revised EWC Directive into national law by 1 January 2028, marking the start of a critical transition period before full application in 2029.

Background

European Works Councils were introduced under the Directive 94/45/EC and later recast through Directive 2009/38/EC. The framework requires multinational companies with at least 1,000 employees within the European Economic Area and at least 150 employees in two or more Member States to establish a mechanism for transnational information and consultation with employee representatives.

Over time, however, concerns emerged regarding the practical effectiveness of EWCs. Stakeholders and policymakers pointed to challenges such as unclear definitions of transnational matters, late or purely formal consultation, and limited access to effective remedies where obligations were not respected.

Against this backdrop, the European Commission proposed a revision of the Directive with the aim of strengthening the role of EWCs, improving legal certainty and ensuring more effective enforcement across Member States.

Renegotiation of EWC agreements: a structural shift

The revised EWC Directive significantly alters the rules governing when EWC agreements must be renegotiated and what happens if negotiations fail. In practice, the new framework will trigger renegotiation possibilities for a wide range of existing agreements.

Removal of pre-1996 (“Article 13”) exemptions

EWC agreements voluntarily concluded before 22 September 1996, often referred to as “Article 13 agreements”, will no longer remain exempt from the rules set forth in the Directive. From 2 January 2029, negotiations may be initiated in previously exempt undertakings at the request of:

  • the existent employee representatives, or
  • at least 100 employees (or their representatives) working in undertakings located in at least two Member States, or
  • central management 

Under the revised framework, the negotiation period is limited to two years. If no agreement is reached within that period, the subsidiary requirements of the Directive will automatically apply.

EWC agreements established under the existing Directives

For EWCs established under Directive 94/45/EC or Directive 2009/38/EC, renegotiation may already be requested from 2 January 2028. The same triggering conditions apply: a request by the EWC itself, by at least 100 employees in at least two Member States, or at the initiative of central management.

Here too, negotiations are limited to a two-year period, after which the subsidiary requirements will apply automatically if no agreement has been concluded.

New EWC agreements

For undertakings or groups that fall within the scope of the Directive (at least 1,000 employees in the Member States and at least 150 employees in each of two Member States), the three-year negotiation period for establishing a new EWC remains unchanged. However, any new agreement concluded must fully comply with the revised EWC Directive from the outset.

Key substantive changes introduced by the revised EWC Directive

The reform is not limited to renegotiation mechanics. It also strengthens the substantive rights of EWCs and clarifies the obligations of central management.

Expanded scope of “transnational matters”

The revised EWC Directive clarifies and broadens the notion of “transnational matters”, which determines when information and consultation at EWC level is required.

A matter qualifies as transnational where it affects employees in more than one Member State, or where a decision taken in one Member State is likely to have a substantial impact on employees in at least one other Member State.

The revised EWC Directive places greater emphasis on the cross-border effects of management decisions, rather than solely on where a decision is formally taken. As a result, measures such as reorganizations, relocations of activities, site closures, or centralization of functions may more readily qualify as transnational where they have consequences for employees in multiple Member States.

Revised assessment of “dominant influence”

The revised EWC Directive broadens the concept of dominant influence, which now may be established through decision-making authority alone, including contractual arrangements such as franchises or licenses, even without ownership or financial participation. This means that a parent company can bring a subsidiary under EWC scope if it effectively controls key business decisions. 

The aim is to prevent circumvention of EWC obligations through complex corporate structures and ensure that all entities under genuine central management influence are properly consulted on transnational matters.

Gender balance obligations

The revised EWC Directive requires EWC agreements to aim for at least 40% representation of each gender, including in any select committee. Where this objective is not met, the EWC must provide written justification. Employers should therefore consider gender balance when establishing or revising EWC agreements to ensure fair representation and demonstrate compliance with the Directive’s equality objectives.

Strengthened information and consultation rights

The revised EWC Directive reinforces both information and consultation obligations. Central management must provide employee representatives with information in a timely manner, in a suitable format, and with sufficient content to allow them to understand and assess the planned measures and their likely effects. 

Consultation must take place before any final decision is taken.

Where the EWC issues an opinion within a reasonable timeframe, central management must provide a reasoned response and must do so before the decision is finalized. This obligation requires genuine engagement and cannot be satisfied by a mere acknowledgement.

Strict limitations on confidentiality

Information may only be classified as confidential where its disclosure would seriously harm the undertaking or group. Any confidentiality restriction must be objectively justified. 

By limiting the use of confidentiality, the Directive aims to enhance transparency and strengthen the EWC’s role in meaningful consultation.

Access to justice and sanctions

Member States must ensure that EWCs are able to initiate judicial (and, where appropriate, administrative) proceedings to enforce their rights. 

Sanctions must be effective, proportionate and dissuasive, considering the gravity, duration, consequences, and intentional or negligent nature of the infringement.

Mandatory cost coverage

Central management must bear all costs relating to the establishment and operation of the EWC, including costs relating to training, expert assistance, interpretation, and legal representation.

What employers should already be doing

Even before national transposition, employers should take proactive steps to prepare:

  • Assess existing agreements: Identify whether agreements are pre-1996 (“Article 13”) or later, and review compliance gaps against the revised EWC Directive focusing on consultation procedures, gender balance, and the definition of transnational matters.
  • Prepare for renegotiation requests: Employees or EWCs may trigger renegotiations as soon as national transposition begins.
  • Exercise caution when negotiating early: Any new or revised agreement must already comply with the revised EWC Directive, even if national implementing legislation is not yet finalized.
  • Plan for increased operational and financial obligations: Anticipate additional meetings, training, expert support, and potential litigation, and allocate budget accordingly.
  • Ensure consultation and gender balance compliance: Make sure EWC composition and processes meet the new requirements, including the 40% gender representation objective.
  • Communicate early and provide training: Keep open communication with employee representatives and train management to understand the new rules and obligations.