COMMISSION STAFF WORKING DOCUMENT EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT Accompanying the document Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on measures facilitating the exercise of rights conferred on workers in the context of freedom of movement for workers
Date: 2013-04-26
Institutions: European Commission
Subjects: access to education, child of migrant, equal treatment, job access, labour mobility, severance pay, social integration, subsidised housing, trade union freedom, vocational training, worker (EU), working conditions

EUROPEAN 
COMMISSION 

Brussels, 26.4.2013  
SWD(2013) 148 final 

COMMISSION STAFF WORKING DOCUMENT 

EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT 

Accompanying the document 

Proposal for a 
DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 

on measures facilitating the exercise of rights conferred on workers in the context of 
freedom of movement for workers 

{COM(2013) 236 final} 
{SWD(2013) 149 final} 

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TABLE OF CONTENTS 

1. 

2. 

3. 

3.1. 

3.2. 

INTRODUCTION ....................................................................................................... 1 

PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES... 1 

PROBLEM DEFINITION ........................................................................................... 4 

The state of play ........................................................................................................... 4 

The problems................................................................................................................ 4 

3.2.1.  Non-compliance with EU law (non-conforming legislation or incorrect application) 

and the effect on EU migrant workers ......................................................................... 1 

3.2.2.  Failure of employers and legal advisors to comply with EU law (unable or unwilling 
to apply EU law correctly) and the effect on EU migrant workers.............................. 1 

3.2.3.  EU migrant workers not having access to information or the means to ensure their 

rights............................................................................................................................. 1 

3.3. 

Causes and drivers........................................................................................................ 1 

3.4.  Who is affected and how.............................................................................................. 1 

3.5. 

Baseline scenario and the need for intervention .......................................................... 1 

4. 

5. 

6. 

6.1. 

6.2. 

6.3. 

6.4. 

6.5. 

7. 

7.1. 

7.2. 

7.3. 

7.4. 

7.5. 

8. 

9. 

ANALYSIS OF SUBSIDIARITY ............................................................................... 1 

POLICY OBJECTIVES............................................................................................... 1 

POLICY OPTIONS ..................................................................................................... 1 

No further action at EU level (Baseline scenario) ....................................................... 1 

Common guidance documents. .................................................................................... 1 

Commission’s recommendation to Member States...................................................... 1 

Directive introducing support measures for EU migrant workers ............................... 1 

Directive introducing enhanced protection for EU migrant workers........................... 1 

ANALYSIS OF IMPACTS ......................................................................................... 1 

Option 1: Baseline scenario ......................................................................................... 1 

Option 2: Guidance documents.................................................................................... 1 

Option 3: Recommendation ......................................................................................... 1 

Option 4: Directive introducing support measures ...................................................... 1 

Option 5: Directive introducing enhanced protection.................................................. 1 

COMPARISON OF OPTIONS ................................................................................... 1 

MONITORING AND EVALUATION ....................................................................... 1 

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COMMISSION STAFF WORKING DOCUMENT 

EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT 

Accompanying the document 

Proposal for a 
DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 

on measures facilitating the exercise of rights conferred on workers in the context of 
freedom of movement for workers 

(Text with EEA relevance) 

1. 

INTRODUCTION 

Freedom of movement for workers is one of the four freedoms on which the Single Market is 
based, along with the free movement of goods, services and capital. It is enshrined in Article 
45 TFEU and has been specified into secondary law through Regulation 492/2011 (formerly 
Regulation 1612/68). 

It means that EU citizens who move to another Member State for employment purposes have 
the right not to be discriminated against on the basis of their nationality as regards: access to 
employment, conditions of employment, access to social and tax advantages, membership of 
trade unions, access to training, access to housing, and access to education for children. 

The present initiative is not intended to create new rights for the EU’s migrant workers, but 
responds to the numerous concerns expressed by various parties on the need to ensure that the 
rights  of  European  citizens  are  real  and  to  remove  obstacles  they  face  when  moving  across 
borders. It fits into the Europe 2020 strategy and the ‘Employment package’ adopted by the 
Commission. 

2. 

PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES 

Studies conducted and reports drawn up by experts in the field of free movement of workers, 
such  as  the  network  of  independent  experts  that  supports  the  activities  of  DG  Employment, 
Social Affairs and Inclusion, have been taken into consideration. 

A public consultation was held from June to August 2011, in which citizens and organisations 
were invited to give their views on the main problems linked to the mobility of EU workers, 
on the current level of protection afforded and on the need for the EU to act in order to help 
workers enjoy their rights fully. 

The issue was discussed within the Advisory Committee on free movement of workers, which 
is composed of representatives of Member States and of social partners at both national and 
European level. 

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3. 

PROBLEM DEFINITION 

3.1. 

The state of play 

The  freedom  of  movement  for  workers  that  has  been  in  place  for  more  than  40  years  is 
underpinned  by  important  and  strong  rights.  The  Court  of  Justice  has  provided  important 
guidance on the interpretation of the relevant provisions. 

Infringement procedures are an important means of ensuring that the rules are applied. They 
lead to changes in non-conforming legislation and general practices. However, they will not 
solve specific cases for the individuals concerned and may not be launched in cases involving 
private entities. 

Unlike  what  happens  at  EU  level  in  other  fields  such  as  discrimination  on  grounds  of  race, 
religion,  age  or  gender,  EU  migrant  workers  who  suffer  discrimination  on  the  grounds  of 
nationality  have  no  further  means  than  relying  on  the  Commission’s  action  and  bringing  a 
case  before  the  national  courts.  The  existing  measures  at  EU  level  are  therefore  limited  as 
regards effective exercise of the rights of individual workers. 

Each  Member  State  decides  what  kind  of  support  and  protection  should  be  provided  to  EU 
migrant workers according to their own legal systems. Support and protection therefore differ 
between  Member  States.  Reports  from  experts  in  the  field  suggest  that  in  countries  where 
nationality  is  explicitly  included  among  the  grounds  of  discrimination  that  are  prohibited, 
protection of EU citizens is stronger.  

There  is  a  lot  of  scope  for  greater  geographical  mobility  between  EU  Member  States: 
according to the EU Labour Force Survey, in 2011 only 3.1 % of the working-age European 
population lived in an EU Member State other than their own.  

3.2. 

The problems 

While the rights relating to free movement of workers are strong, a number of indicators show 
that discrimination on the grounds of nationality takes place and that it is difficult for workers 
to exercise their rights in practice. The following problems have been identified: 

3.2.1.  Non-compliance  of  public  authorities  with  EU  law  (non-conforming  legislation  or 

incorrect application) and the effect on EU migrant workers 

The rules on free movement of workers have been in force for more than 40 years. In spite of 
this, problems due to non-compliance of national legislation and general practices persist in 
Member  States  and  continue  to  be  reported  to  the  Commission.  These  problems  can  have 
severe  negative  consequences  for  EU  citizens,  as  they  may  affect  their  job  prospects,  their 
working  conditions  or  their  access  to  social  advantages,  and  disrupt  their  lives  at  both 
professional and personal levels. They also affect the integration of EU citizens in the labour 
market and in the society of the host country. While these problems may be addressed at EU 
level  through  infringement  procedures,  this  will  not  have  a  direct  effect  on  the  individuals 
concerned. 

3.2.2.  Failure of employers and legal advisors to comply with EU law (unable or unwilling 

to apply EU law correctly) and the effect on EU migrant workers 

Cases have been reported where public and private employers have failed to respect the EU 
rules,  regardless  of  whether  the  legislation  at  national  level  is  correct  or  not.  Information 
collected by experts and by the Commission suggests that this problem is recurrent, although 
awareness of such problems depends very much on the level of publicity given to these cases. 
Problems due to action taken by private employers cannot be addressed at EU level through 
the infringement procedure. Therefore, citizens who suffer from discrimination may only rely 

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on the mechanisms and means available at the national level. Actions of employers can have 
severe  consequences  for  the  personal  situation  of  the  workers  concerned,  hindering  their 
employment chances and/or affecting their working conditions. 

3.2.3.  EU migrant workers not having access to information or the means to ensure their 

rights 

Respondents to various surveys have said that they do not know where to turn to when faced 
with  problems  concerning  their  EU  rights.  This  indicates  that  there  is  no  clear  point  of 
reference for EU citizens. Lack of clarity about the best place to obtain information about EU 
rights  was  also  mentioned.  It  is  also  difficult  for  EU  workers  exercising  their  right  to  free 
movement , due to a number of factors (such as not knowing the procedures, not knowing the 
national systems,  lack  of linguistic abilities), to avail themselves of the means of protection 
available. This was confirmed by the results of the public consultation, where a majority of 
citizens stated that the level of protection afforded to workers would strongly influence their 
decision to go and work in another Member State. Reluctance to report discrimination is also 
an important factor. 

3.3. 

Causes and drivers 

Four  main  drivers  have  been  identified:  (1)  unawareness  of  the  rights  of  EU  workers  under 
EU law and unawareness of the means of redress available; (2) lack of understanding of EU 
law  and  lack  of  legal  certainty;  (3)  insufficient  support  to  enable  EU  migrant  workers  to 
exercise their rights; (4) protectionism and unwillingness to comply. 

3.4.  Who is affected and how 

The  problems  identified  affect  EU  citizens  who  move  to  another  Member  State  for 
employment purposes, including jobseekers and citizens of a given Member State who have 
exercised their right to free movement and come back to their Member State of origin in order 
to work. 

On average, 67.9 % of the EU working-age citizens who live in another Member State are in 
employment and 9.1 % are unemployed. So, theoretically, all of them may at some point have 
problems relating to the effective application of rights. Those citizens who intend to move in 
the future (17 %) may also be affected. 

The problems may concern all EU workers and all occupations and sectors of activity. Family 
members may also be affected, as they have certain rights under the EU provisions. 

Employers  and  national  authorities  may  be  affected  too,  as  better  enforcement  of  migrant 
workers’ rights might mean that they incur costs. 

3.5. 

Baseline scenario and the need for intervention 

In  the  current  economic  and  social  context,  further  limitations  on  the  rights  of  EU  migrant 
workers  cannot  be  excluded.  Specific  actions  identified  across  Europe  and  various  surveys 
show  that  there  is  increasing  intolerance  towards  EU  migrant  workers,  which  may  translate 
into discriminatory actions. 

Following the enlargements of 2004 and 2007, workers form other Member States are faced 
with new problems of application of EU law and this requires a more pedagogical approach in 
the field of free movement. 

The present initiative can help encourage and facilitate mobility, as fighting discrimination on 
grounds  of  nationality  will  send  a  positive  signal  to  those  who  wish  to  work  in  another 
Member State, and will mean that fewer people are discouraged from moving because of bad 
experiences or because they expect to find problems. 

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4. 

ANALYSIS OF SUBSIDIARITY 

Article 46 TFEU establishes the Union’s competence to issue directives or regulations setting 
out measures required to bring about freedom of movement for workers, as defined in Article 
45 TFEU. 

The present initiative will allow Member States to adopt appropriate implementing measures, 
thus  respecting  the  principle  of  proportionality.  Member  States  which  already  have  detailed 
legal  protection  against  discrimination  on  the  grounds  of  nationality  will  not  need  to  make 
major changes to their own systems. 

Achievement of the objectives of this initiative would help consolidate the fundamental rights 
set out in the Charter of Fundamental Rights of the European Union. 

5. 

POLICY OBJECTIVES 

The present initiative ties in with the general objective of ensuring that EU citizens are treated 
equally.  This  is  one  of  the  core  values  of  the  European  Union  and  a  major  part  of  EU 
citizenship.  Ensuring  that  this  goal  is  achieved  will  help  the  internal  market  to  run  more 
smoothly. 

The following specific objectives have been identified: 

– 

– 

reducing discrimination of EU migrant workers on the grounds of nationality;  

narrowing  the  gap  between  the  rights  on  paper  and  their  exercise  in  practice,  thus 
helping  to  achieve  full  and  correct  implementation  of  the  existing  legislation  and 
allowing the internal market to run more smoothly. 

In order to meet these policy objectives, operational objectives have been identified: 

– 

– 

– 

increasing  awareness  among  citizens,  employers,  public  authorities  and  other 
stakeholders about EU migrant workers’ rights; 

improving legal certainty; 

giving EU workers the appropriate tools of support when exercise their rights. 

6. 

POLICY OPTIONS 

The following options have been identified: 

6.1. 

6.2. 

No further action at EU level (Baseline scenario) 

Common guidance documents 

This option would be focused on the adoption of common guidelines by Member States and 
the Commission in order to have a common approach to the application and interpretation of 
EU  rules  on  free  movement  of  workers.  It  would  be  complemented  by  interpretative 
documents adopted by the Commission. 

6.3. 

Commission Recommendation to Member States. 

This option would consist of the adoption of a general recommendation by the Commission 
addressed to Member States in order to encourage them to take action for: 

– 

– 

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increasing awareness of EU migrant workers’ rights; 

increasing  the  support  given  to  EU  migrant  workers,  by  requesting  that  means  of 
redress  be  provided,  setting  up  supportive  structures  for  EU  migrant  workers  and 

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allowing associations and organisations to take legal action on behalf or in support of 
EU migrant workers. 

6.4. 

Directive introducing support measures for EU migrant workers, in particular: 

- a legal obligation to provide EU migrant workers with means of redress; 

-  the  setting  up  of  structures  providing  support to  EU  migrant  workers.  This  would  involve 
promotion  of  rights,  assistance  to  EU  migrant  workers  in  enforcing  their  rights,  conducting 
surveys, drawing up reports and adopting recommendations; 

- ensuring that associations, organisations or legal entities with an interest in the promotion of 
the right to free movement of workers may engage in any administrative or judicial procedure 
on behalf or in support of EU migrant workers. 

6.5. 

Directive introducing enhanced protection for EU migrant workers 

In addition to the elements described under policy option 4, this option would also introduce: 

- an obligation for employers to prevent discrimination within their undertakings; 

- measures imposing sanctions or compensation; 

- a legal provision aimed at protecting EU migrant workers against any adverse treatment as a 
result of making a complaint. 

7. 

ANALYSIS OF IMPACTS 

From  an  economic  perspective,  it  has  not  been  possible  to  identify  any  impacts  other  than 
those  that  will  naturally  stem  from  the  expected  social  impacts  and  the  actual  costs  of 
implementation.  Reducing  discrimination  on  the  grounds  of  nationality  in  regard  to 
employment  might  make  intra-EU  mobility  more  attractive.  While  the  increase  in  mobility 
may not be substantial, as discrimination is only one of the factors that influence a person's 
decision  to  move,  its  effects  on  the  functioning  of  the  Single  Market  will  be  positive,  as 
mobility can play a role in economic growth. 

7.1. 

Option 1: Baseline scenario 

Social impact 

The  identified  problems  and  drivers  would  remain  unaddressed.  It  would  involve  no 
significant  change  in  national  authorities’  and  employers’  behaviour.  There  would  be  no 
substantial  impacts  on  awareness  of  rights  and  legal  certainty.  Maintaining  the  status  quo 
would furthermore mean that there would be no minimum consolidated support or EU-level 
protection  of  migrant  workers.  It  would  continue  to  affect  negatively  the  individuals  who 
move  for  employment  purposes  and  would  perpetuate  the  limited  ability  of  EU  migrant 
workers to participate fully in the labour market and society of the host Member State. 

Economic impact 

No implementation costs have been identified. 

7.2. 

Option 2: Common guidance documents 

Social impact 

The adoption of guidance would entail a common interpretation of the current EU rules with a 
view to their practical implementation by national administrations. It would thus contribute to 
increasing legal certainty and reducing the implementation gaps. It might also result in fewer 
instances of discrimination. 

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The  guidance  would  also  help  raise  awareness  among  national  authorities  about  the  rights 
linked  to  free  movement  of  workers  but  would  depend  on  the  publicity  and  dissemination 
given in each Member State. 

The guidance would focus on questions of interpretation of EU law but would not contain any 
specific  measure  providing  assistance  and  support  to  workers.  Therefore,  although  it  can 
induce workers to use their rights more fully because of greater legal certainty, it will not help 
them enforce those rights when problems arise. 

Its overall social impact would therefore be positive but limited. 

Economic impact 

This  option  might  involve  some  implementation  costs  linked  to  the  dissemination  and 
publication  of  the  guidance,  including  translation  costs.  Costs  will  depend  on  the  specific 
efforts made by Member States in this regard. 

This  option  could  reduce  the  level  of  misapplication  of  EU  law  by  national  administrations 
but  it  would  not  be  relevant  to  a  wider  range  of  stakeholders  and  therefore  it  might  have  a 
limited impact on the number of complaints and court procedures. 

No implementation costs have been identified for enterprises. 

7.3. 

Option 3: Commission Recommendation to Member States 

Impacts of this option might be potentially the same as in policy option 4, as the same issues 
will  be  addressed.  The  difference  between  the  options  and  therefore  their  correspondent 
impacts lies in their binding or non-binding nature. 

Social impact 

The  recommendation  would  give  the  issue  a  certain  visibility  which  could  improve  the 
awareness  of  rights  among  citizens,  relevant  stakeholders  and  national  authorities.  It  could 
increase  involvement  of  the  national  authorities  in  reducing  implementation  gaps  and  help 
strengthen the support and help mechanisms available to EU migrant workers. 

The  recommendation  would  not  impose  any  obligation  on  Member  States.  Taking  into 
account  the  different  perceptions  and  actions  in  the  field  of  free  movement  of  workers  and 
their  rights,  there  is  a  risk  of  increased  diversity  in  the  way  problems  are  addressed  in  the 
Member States. 

The  social  impact  might  therefore  be  positive  but  it  will  depend  on  the  degree  of 
implementation in each Member State, and increased diversity might reduce the advantages. 

Economic impact 

Impacts including costs will depend on the specific actions taken by Member States. 

7.4. 

Option 4: Directive introducing support measures for EU migrant workers 

Social impact 

Linking  means  of  redress  specifically  to  matters  of  discrimination  on  the  grounds  of 
nationality would increase the level of legal certainty, as citizens would be sure that specific 
procedures are available to them no matter which Member State they decide to move to and 
work in. 

Addressing  nationality  as  a  ground  of  discrimination  through  specialised  bodies,  without 
making  protection  against  this  kind  of  discrimination  dependent  on  generous  interpretations 
of the law applicable in other fields, would increase legal certainty. 

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The  efforts  of  the  supporting  bodies  (surveys,  reports,  recommendations)  would  help  to 
increase  awareness  and  to  end  discriminatory  laws  and  practices.  As  they  would  offer  EU 
migrant workers advice and assistance, they can also be expected to encourage such workers 
to assert their rights. Setting up similar bodies throughout the European Union would ensure 
that citizens can have access to support and information in every Member State. The fact that 
associations  and  organisations  could  take  legal  action  would  be  another  incentive  for  EU 
migrant workers to assert their rights. 

The supporting bodies will also be in a position to assist enterprises  and trade unions when 
they need advice on specific questions related to migrant workers’ rights. Making provision 
for  associations  and  organisations  to  take  legal  action  would  increase  the  number  of 
stakeholders involved in the fight against discrimination on grounds of nationality. 

Overall the social impact will be positive, as discrimination on the basis of nationality should 
be reduced. 

Economic impact 

The  setting  up  of  supporting  bodies  would  involve  implementation  costs  for  national 
authorities. However, as it will be left to Member States to designate the bodies concerned, 
the actual costs will vary according to whether a new structure is created or whether the new 
tasks  are  assigned  to  already  existing  bodies.  All  27  Member  States  currently  have  specific 
structures for dealing with discrimination on other grounds; therefore if they decide to confer 
on  them  the  task  of  fighting  discrimination  on  grounds  of  nationality,  the  implementation 
costs would be limited to extension of their role. 

The measures proposed are expected to have a preventive effect and reduce the need to rely 
on court procedures to resolve disputes, as seems to be the case in countries where supporting 
bodies covering discrimination on the grounds of nationality already exist. 

While no implementation costs have been identified for enterprises, this option would involve 
some costs for associations and organisations that will be allowed to take legal action, as they 
will have to bear the costs linked to the legal procedures. 

7.5. 

Option 5: Directive introducing enhanced protection for EU migrant workers 

The provisions that would be adopted under this policy option, in addition to those foreseen 
under option 4, would also impose some obligations on employers. 

Social impact 

Active  measures  to  prevent  discrimination  would  be  directly  applicable  in  the  relevant 
context, namely at the workplace. That means  there would be certainty that the information 
reaches  its  addressees.  Sanctions  and  compensation  to  victims  would  also  increase  legal 
certainty, as a set of rights and obligations would be created. 

The  information  obligation  and/or  active  measures  to  prevent  discrimination  would  make 
equal treatment a part of companies’ human resources policy, thereby raising awareness of the 
applicable  rights  among  national  workers  and  entrepreneurs  and  also  the  sensitivity  of  the 
issue. 

Measures  for  prevention  of  discrimination  are  by  their  nature  intended  to  do  away  with 
discriminatory  practices.  The  threat  of  sanctions  may  deter  employers  from  acting  in  a 
discriminatory way. 

Introducing  provisions  on  victimisation  would  put  individual  workers  in  a  stronger  position 
and make them more assertive about their rights. 

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The  provisions  of  this  policy  option  would  help  reduce  discrimination  on  the  basis  of 
nationality by a combined approach of incentivising workers to exercise their rights (option 4) 
and introducing prevention of discrimination. 

While  the  elements  envisaged  would  send  an  important  message  to  society  about  fighting 
discrimination,  it  has  not  been  possible  to  show  whether  they  will  in  practice  have  a 
significant effect on the individuals concerned. 

Economic impact 

Implementation  costs  for  national  authorities  are  the  same  as  under  policy  option  4.  The 
number of court cases might change, but this is very uncertain; furthermore, short- and long-
term  effects  might  be  completely  different.  Therefore,  it  was  not  possible  to  include  this 
aspect in the analysis. 

This  policy  option  would  involve  compliance  costs  for  employers,  which  would  mainly 
consist  of  man-hour  costs  associated  with  taking  active  measures,  e.g.  for  training  facilities 
and  activities.  It  is  difficult  to  provide  proper  estimates  of  those  costs,  as  they  will  vary 
according to the measures taken by employers. For the most part they can be expected to vary 
with the size of the enterprise, while a small fixed-cost component would be independent of 
the size of the company. 

Implementation  costs  will  also  arise  from  the  provisions  on  sanctions/compensation. 
However,  establishment  of  the  specific  amount  will  be  left  to  each  Member  State.  The 
specific economic and financial impacts will therefore depend on each Member State. 

8. 

COMPARISON OF OPTIONS 

The options have been compared with regard to their effectiveness in achieving the specific 
objectives of the initiative, their efficiency, consistency with the general objectives of the EU 
and their impacts on stakeholders. 

The preferred option is a combination of options 2 and 4. They are a bit less effective  than 
policy  option  5  but  this  approach  is  the  most  efficient.  Together,  these  options  provide  a 
comprehensive  solution  to  all  the  specific  problems  identified  without  involving  excessive 
compliance costs. They are more consistent with the general objectives than option 5, which 
puts disproportionate costs on companies. They are also the most predictable options in terms 
of their effects. 

9. 

MONITORING AND EVALUATION 

Several indicators, both quantitative (e.g. the number of complaints) and qualitative (e.g. the 
reports from the network of experts), will be used for monitoring purposes, together with the 
reports, surveys and recommendations produced by the supporting bodies that will be set up 
according to this initiative. 

Two  years  after  the  transposition  deadline,  an  evaluation  will  be  carried  out  by  the 
Commission with the assistance of external experts. The evaluation will assess: 

– 

– 

awareness  among  citizens  and  stakeholders  of  the  existence  of  the  elements 
introduced through the Directive; 

the activities carried out by the supporting bodies, and the role of other organisations 
and associations; 

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– 

the types of discrimination most commonly dealt with and whether this has changed 
as compared to the status quo. 

Overall,  this  evaluation  should  assess  whether  the  newly  introduced  elements  have  led  to 
positive changes and identify the difficulties faced so far. 

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