REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS on the implementation of Decision (EU) 2016/344 establishing a European Platform for enhancing cooperation in tackling undeclared work
Date: 2020-04-02
Institutions: Directorate-General for Employment, Social Affairs and Inclusion, European Commission
Subjects: EU Member State, EU employment policy, EU office or agency, clandestine worker, cross-border cooperation, exchange of information, institutional cooperation, labour inspectorate, moonlighting, operation of the Institutions

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 2.4.2020  COM(2020) 129 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS on the implementation of Decision (EU) 2016/344 establishing a European Platform for enhancing cooperation in tackling undeclared work     
 
 
1. 

INTRODUCTION  

Undeclared work, understood as any paid activities that are lawful as regards their nature but 
not declared to public authorities1, can take various forms, ranging from a complete lack of 
documentation  to  under-reporting  of  hours,  envelope  wages  and  bogus  self-employment. 
Undeclared work puts workers at a multitude of risks, undermines public finances and wider 
social  cohesion.  In  a  fast  changing  and  increasingly  mobile  labour  market,  it  fuels  social 
dumping  and  distorts  fair  competition  within  and  between  Member  States.  On  average, 
undeclared  work  is  estimated  to  represent  about  14.3%  of  gross  value  added  (GVA)  in  the 
private sector in the EU, with large variation across Member States2. A recent Eurobarometer 
survey also shows that around one in ten Europeans (10%) reported having acquired goods or 
services,  which  they  believe  involved  undeclared  work,  in  the  past  year.  3%  say  they 
themselves have carried out undeclared activities in the last twelve months although a third 
know someone who has3.  

Tackling  undeclared  work  requires  a  holistic  approach  combining  policies  in  various  fields 
(such as labour law, social security, taxes) and their implementation through both deterrence 
(e.g. inspections and sanctions) and prevention measures (such as better information).  Policy 
measures’ effectiveness  varies importantly between Member States. Besides, while tackling 
undeclared work is primarily in the hands of national authorities, this persistent challenge has 
an important cross-border dimension.  

The  European  Platform  tackling  undeclared  work  was  launched  in  2016  to  enhance 
cooperation  between  Member  States  in  tackling  undeclared  work,  under  Decision  (EU) 
2016/3444.  In  a  context  where  cooperation  across  borders  used  to  be  mostly  ad  hoc,  the 
Platform  has  acted  as  a  catalyst  for  change.  It  has  brought  together  Member  States’ 
enforcement  authorities  and  social  partners  into  a  unique  network  to  learn  from  each  other 
and  act  together,  contributing  to  a  fairer  European  labour  market.  In  doing  so,  it  also 
contributed to delivering on the European Pillar of Social Rights.  

In  the  area  of  labour  mobility,  an  important  recent  development  has  been  the  setting  up  in 
2019 of the European Labour Authority5 (ELA),  which will ensure that EU rules on labour 
mobility are enforced in a fair, simple and effective way. Regulation (EU) 2019/1149 of the 
European  Parliament  and  of  the  Council  of  20  June  2019  establishing  a  European  Labour 
Authority foresees the integration of the Platform into ELA as a permanent working group, 
which will presumably take place in  20216. This  move will allow the Platform  activities in 
the  area  of  tackling  undeclared  work  to  benefit  from  ELA’s  broader  enforcement  and 
prevention  perspective  and  to  develop  synergies  to  other  ELA  tasks  such  as  information 
provision,  joint  and  concerted  inspections  and  capacity  building.  The  launch  on  2  March 
2020  of  the  first  European  campaign  for  declared  work,  #EU4FairWork,  with  the 
participation of the ELA, is an important step in this respect.  

1 Commission Communication 'Stepping up the fight against undeclared work', COM(2007)628 
2  Williams,  C.C.,  Horodnic,  I.A.,  Bejakovic,P.,  Mikulic.  D.,Franic,  J.,  Kedir,  A.  (2017)  An  evaluation  of  the  scale  of 
undeclared work in the European Union and its structural determinants: estimates using the Labour Input Method (LIM) 
3 Special Eurobarometer survey 498, Undeclared Work in the EU, September 2019 
4  Decision  (EU)  2016/344  of  the  European  Parliament  and  of  the  Council  of  9  March  2016  on  establishing  a  European 
Platform to enhance cooperation in tackling undeclared work  
5 https://ela.europa.eu/index.html 
6  Regulation  (EU)  2019/1149  of  the  European  Parliament  and  of  the  Council  of  20  June  2019  establishing  a  European 
Labour Authority, amending Regulations (EC) No 883/2004, (EU) No 492/2011, and (EU) 2016/589 and repealing Decision 
(EU) 2016/344 

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This  report  on  the  application  and  the  added  value  of  Decision  (EU)  2016/344  reviews 
progress  achieved  in  its  implementation,  following  on  from  the  Platform's  Biennial  Report 
adopted in 20187. Pursuant to Article 12 of the Decision, it assesses the extent to which the 
Platform has achieved the objectives in Article 4, fulfilled its mission as set out in Article 5, 
carried out the activities in Article 6 and addressed the priorities in its work programme. The 
report integrates the results from a specific survey among Platform members in 2019 as well 
as ongoing monitoring of Platform activities.  

The European Platform tackling undeclared work, in a nutshell 

The  European  Platform  tackling  undeclared  work  (hereafter  ‘the  Platform’)  was  set  up  in 
2016  to  enhance  cooperation  between  Member  States,  further  to  the  2003  Council 
Resolution and 2007 Commission Communication on tackling undeclared work8.  

It  aims  at  contributing  to  more  effective  EU  and  national  actions  by  a)  enhancing 
cooperation  between  Member  States’  relevant  authorities  and  other  relevant  actors,  b) 
improving  the  capacity  of  Member  States’  relevant  authorities  and  actors  to  tackle 
undeclared work with regard to cross-border aspects, and c) increasing public awareness of 
issues  relating  to  undeclared  work  and  encouraging  Member  States  to  step  up  their  efforts 
(Article  4  ’Objectives’).  These  objectives  should  be  achieved  through  a)  exchanging  best 
practices  and  information;  (b)  developing  expertise  and  analysis;  (c)  encouraging  and 
facilitating  innovative  approaches  to  effective  and  efficient  cross-border  cooperation  and 
evaluating experiences; (d) contributing to a horizontal understanding of matters relating to 
undeclared work (Article 5 ‘Mission’). 

The Platform brings together over 50 stakeholders. Members are senior representatives from 
ministries  and  enforcement  authorities  (labour  inspectorates,  tax  and  social  security 
authorities), as  well as  cross-sectoral  social  partners. They act  as a single point of contact, 
liaising with national stakeholders and disseminating learning outcomes. Observers include 
14 social partner organisations from key sectors, as well as Eurofound, the European Agency 
for  Safety  and  Health  at  Work  and  the  International  Labour  Organisation,  Norway  and 
Iceland as members of the European Economic Area. The Bureau, consisting of a chair from 
the  Commission  and  two  co-chairs  elected  among  senior  representatives,  steers  the 
Platform’s work and gives strategic direction, with support from the Secretariat, based at the 
Commission. The Platform’s plenary meets twice a year.  

An  annual  budget  of  EUR  1.35  million  under  the  EU  Programme  for  Employment  and 
Social  innovation  (EaSI)  supports  the  Platform.  In  addition,  five  cross  border  cooperation 
projects on tackling undeclared work have been supported (through EaSI) following calls for 
proposals for an amount of  EUR 1.67 million, contributing to the Platform’s objectives.   

2.  PROGRESS IN FULFILLING PLATFORM MISSION AND DELIVERING ACTIVITIES   

After  the  Platform  adopted  its  initial  work  programme  in  May  2016,  activities  kicked  off 
smoothly.  It  has  since  delivered  on  average  15  yearly  activities  and  brought  together  over 

7  Biennial report  https://ec.europa.eu/social/BlobServlet?docId=20472&langId=en 
8  Council  Resolution  on  transforming  undeclared  work  into  regular  Employment  (2003/C  260/01)  and  European 
Commission Communication ‘Stepping up the fight against undeclared work’ (COM(2007)628) 

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1450  stakeholders  to  learn  together  and  cooperate  on  issues  ranging  from  promising  policy 
approaches to organisational structures and cross-border action.  

This  section  reports  on  these  activities  and  how  they  contributed  to  delivering  on  the 
Platform's  mission  (article  5).  It  is  structured  along  and  highlights  how  the  Platform  has 
addressed  the  three  strategic  priorities  identified  in  its  2017-2018  and  2019-2020  work 
programmes9,  namely  1)  cooperation  and  joint  action,  2)  mutual  learning  and  3)  increasing 
knowledge.  

Overview of Platform activities since 201610 

Most Platform members and observers (84%) share the opinion that the Platform made good 
or very good progress towards the achievement of its mission according to the 2019 survey11. 
Among  the  main  activities  contributing  to  this,  are:  seminars  (84%),  thematic  review 
workshops (74%), working groups (68%), staff learning visits (45%).  

2.1.  Cooperation and joint action  

Between  its  start  in  2016  and  the  end  of  2019,  the  Platform  organised  31  staff  visits  and 
joint  activities  in  14  hosting  countries,  whereby  travel  and  accommodation  were  covered 
through  the  contract  supporting  the  Platform.  They  were  used  specifically  to  support  joint 
inspections carried out in one country with participation of other national authorities (42%), 
mostly  in  the  construction  and  agriculture  sectors.  Other  types  of  visits  (e.g.  learning 
exchange,  training,  joint  activities)  helped  members  build  a  deeper  knowledge  on  a  topic, 
practice  or  process  through  first-hand  and  practical  learning  experience.  They  addressed  in 
particular  issues  related  to  enforcement  bodies'  organisational  structures;  risk  assessment, 
data  mining  and  analysis;  information  systems,  databases  and  online  tools  for  information 
sharing; fraudulent posting of workers. Staff learning visits are considered by around half of 

9 The 2017-2018 and 2019-2020 Work Programmes can be found on the following links: 
https://ec.europa.eu/social/BlobServlet?docId=22305&langId=en, 
https://ec.europa.eu/social/BlobServlet?docId=16358&langId=en.  
10 Figures cover activities up to the end of 2019 
11 In total 31 Platform members and observers responded to the 2019 satisfaction and take-up survey, including 27 Platform 
members representing their Member State; as well as 1 observer and 3 social partner representatives 

3 

 
 
 
                                                           
respondents to the 2019 survey as one of the top five activities contributing to achieving the 
Platform’s objectives and mission.  

Supporting a joint inspection in the agricultural sector in Spain 

In July 2019, the Spanish Labour Inspectorate invited the Romanian Labour Inspectorate, 
along  with  the  Spanish  and  Romanian  police,  to  carry  out  joint  inspections  during  the 
garlic  harvesting  season  in  Albacete,  with  operational  support  from  the  Platform. 
Interviews  and  inspections  were  carried  out  with  Spanish  employers,  Spanish  temporary 
employment agents, and Romanian intermediaries. More than 500 workers were identified 
and informed about their rights. Investigations are on-going, with four people arrested for 
human trafficking crimes and labour exploitation.  

A  total  of  seven  working  groups  brought  together  members  of  the  Platform  in  a  joint 
reflection  on  fundamental  issues  they  face,  giving  them  an  active  role  in  shaping  Platform 
activities.  The  groups  have  developed  a  variety  of  practical  outputs,  such  as  a  proposal  for 
stepping up information  exchange between national authorities through a potential  Internal 
Market Information System module on undeclared work, as well as a glossary of terms and 
measures  for  tackling  undeclared  work.12  Other  working  groups  have  developed  the 
Platform’s  work  programme  and  responded  to  national  and  social  partner  priorities.  Most 
Platform  members  (68%)  consider  working  groups  as  one  of  the  top  five  activities 
contributing to the Platform’s objectives and mission. 

Mutual assistance projects (MAPs) have been  successfully delivered in Bulgaria, Cyprus, 
Greece,  Latvia,  Lithuania,  Romania  and  Slovakia13.  They  have  given  members  the 
opportunity to be counselled by a team of Platform experts in strategic areas of enforcement 
authorities.    These  projects  often  arose  out  of  national  priorities  for  structural  reform, 
including 
country-specific 
recommendations. An approach involving self-reflection, practical support from peers during 
two  visits  and  the  development  of  an  action  plan  has  helped  to  bring  about  significant 
changes, such as the design of new measures and enhanced cooperation between enforcement 
bodies. The 2019 survey indicated that this is one of the activities that contributed the most to 
fulfilling the Platform’s mission.  

the  European  Semester 

highlighted 

through 

those 

Mutual assistance outcomes in Latvia 

Further to a 2017 Platform mutual assistance project visit in 2017, the Latvian State Labour 
Inspectorate revised its strategy on undeclared work, modernised strategic objectives and 
adopted  new  key  performance  indicators.  The  outcome  has  been  a  shift  towards  more 
emphasis  on  preventative  measures.  Focus  is  now  on  transforming  undeclared  work  into 
declared work, with 74% of all identified cases of undeclared work now being transformed 
into declared work14.  

12 Available on: https://ec.europa.eu/social/main.jsp?catId=1323&langId=en  
13 Support to Belgium is planned in 2020 
14 This can include for instance ensuring undeclared workers receive a formal labour agreement.  

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2.2.  Mutual learning    

Mutual learning and the systematic exchange of information have been key to the Platform’s 
activities,  contributing  to  improve  the  effectiveness  of  efforts  to  tackle  undeclared  work 
across the EU.  

Platform  seminars  have  explored  pressing  issues  and  emerging  practices  (e.g.  prevention, 
holistic  approaches  to  tackle  undeclared  work,  awareness-raising),  as  well  as  key  sectors 
affected  by  undeclared  work  (e.g.  construction,  agriculture,  transport).  The  findings  from 
these events were documented in learning resource papers which are publicly available on the 
Platform’s website15.  

Six thematic review workshops have supported members in improving their efficiency and 
stepping  up  cross-border  cooperation,  through  more  in-depth  mutual  learning  and  problem-
solving (which include a follow-up visit and the production of a toolkit for practitioners). The 
selected  themes  included  bilateral  agreements  and  memorandums  of  understanding;  data 
mining;  risk  assessment;  outreach  to  workers  and  companies;  cross-border  concerted  and 
joint  actions,  and  the  future  role  and  competence  profile  of  labour  inspectorates.  Platform 
seminars (84%) and thematic review workshops (74%) were frequently indicated as activities 
contributing the most to fulfilling the Platform’s mission in the 2019 survey.  

Sharing ideas and transforming effective practices in Greece 

The thematic review workshop on risk assessment that took place in Spain in 2018 inspired 
the Hellenic Labour Inspectorate (HLI) to refine its Risk Analysis Tool to improve detection 
of  illegal  employers.  The  HLI  used  this  new  risk  assessment  method  to  send  notification 
letters  to  businesses  potentially  at  risk.  The  announced  inspections  letters  resulted  in  an 
increase  of  31  %  in  the  number  of  full-time  contracts  declared  in  the  first  month  after  the 
letter was sent. 

In addition, the biannual plenary meetings allocated a thematic day to discuss a particular 
area of undeclared work and potential successful policy approaches. These include priorities 
highlighted  in  the  Decision  establishing  the  Platform  such  as  letterbox  companies,  data 
protection and data exchange. 

2.3.  Increasing knowledge  

Finding solutions to tackle undeclared work is complex, and expanding the knowledge-base 
on all its aspects  contributes to  the expertise of relevant  actors on specific issues related to 
undeclared work. The Platform has produced new knowledge on specific types of undeclared 
work  (e.g.  envelope  wages,  undeclared  work  in  the  collaborative  platform  economy,  bogus 
self-employment) as well as measures to prevent and deter them, with more than 100 learning 
resources and 120 fiches presenting good practices.   

Overall, 14 studies and surveys have been published, contributing to a more evidence-based 
approach.  These  have  synthesised  existing  expertise  and  produced  new  knowledge  on 

15 https://ec.europa.eu/social/undeclared-work-platform 

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specific  types  of  undeclared  work,  emerging  trends  and  policy  approaches.  As  per  the 
priorities  set  out  in  the  Decision,  the  focus  of  these  studies  has  included  bogus  self-
employment,  under-declared  employment,  data  protection  and  exchange  of  information, 
preventative  approaches,  cross-border  cooperation,  and  documenting  stories  of  social 
partners’  successful  engagement.  The  studies  and  surveys  produced  by  the  Platform  have 
harnessed  collective  experiences  and  know-how  to  put  forward  evidence-based  solutions. 
However,  only  32%  of  the  Platform  members  place  them  among  the  top  five  activities 
contributing  to  the  Platform’s  objectives  and  mission.  Translation  was  suggested  as  way 
forward to improve their usefulness. 

 The scale of undeclared work 

The magnitude of undeclared work in Europe is difficult to estimate given that, by definition, 
it is hidden from view. As a first step, factsheets summarised the characteristics of undeclared 
work across all EU countries, and the institutions involved in addressing it16. A study on the 
scale  of  undeclared  work  across  Europe  was  also  produced  in  2017.  Based  on  the 
discrepancies  between  the  reported  labour  inputs  from  workers  and  businesses,  the  study 
estimated that 9.3% of total labour input in the private sector in the EU is undeclared work, 
and  that  undeclared  work  constitutes  14.3%  of  gross  value  added  (GVA)  in  the  private 
sector.17  However,  there  are  marked  differences  in  its  size  across  Member  States,  ranging 
from 7% to 27% of GVA.   

2.4.  Communication activities 

The  Platform  has  developed  evidence-based  resources  on  how  best  to  tackle  undeclared 
work.  Its  virtual  library18  contains  valuable  information  and  practices  generated  by  the 
Platform’s work. A biannual newsletter, sent out after the plenary meetings, provides an up-
date  to  interested  stakeholders  on  the  Platform,  activities  and  members.  For  internal 
communication, Platform members and observers share documents and announce events on 
their own collaborative workspace. On 2 March, the Platform launched #EU4FairWork, the 
first European campaign for declared work.  

2.5.  Thematic scope of the Platform: building evidence on a wide range of issues 

Over its first years of operations, the Platform has consolidated knowledge and built further 
evidence on a wide array of issues, ranging from policy approaches to strategic management 
and cross-border cooperation.  

16 https://ec.europa.eu/social/main.jsp?catId=1322&langId=en 
17  Williams,  C.C.,  Horodnic,  I.A.,  Bejakovic,P.,  Mikulic.  D.,  Franic,  J.,  Kedir,  A.  (2017)  An  evaluation  of  the  scale  of 
undeclared  work  in  the  European  Union  and  its  structural  determinants:  estimates  using  the  Labour  Input  Method  (LIM), 
available on http://ec.europa.eu/social/BlobServlet?docId=18799&langId=en  
18 https://ec.europa.eu/social/undeclared-work-platform 

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Some key topics addressed through learning activities 

Effective approaches: lessons learnt 

Key elements of successful approaches, highlighted in the first years of operation, include:   

Collaboration:  Responsibility  for  tackling  undeclared  work  usually  lies  with  multiple 
government departments, which can result in the lack of a coordinated approach. The extent 
to  which  Member  States  involve  social  partners  is  often  limited  to  mutual  exchange  and 
consultation.  A  cross-agency  strategic  approach  provides  better  access  to  data  and 
information, helps develop mutual understanding, joint strategies and concrete actions. 

Focusing efforts and resources - risk assessment and data analysis: Some Member States 
have  developed  risk  assessment  models,  enabling  enforcement  authorities  to  highlight  the 
riskiest cases of undeclared work. This approach targets resources effectively and improves 
the  success  rates  of  inspections.  Using  data  more  effectively  is  an  essential  part  of  risk 
assessment.  

Combining  deterrent  and  preventative  approaches:    There  is  a  need  to  develop  an 
approach  which  combines  more  effective  controls  and  enforcement  after  undeclared  work 
has occurred, with measures to prevent it from arising in the first place. Platform members 
are  using  a  range  of  different  preventative  approaches  including  supply-side  and  demand-
side incentives, awareness raising campaigns (aimed at employers, workers and the public) 
as well as reforming institutions to support this.  

Holistic approaches, using a range of measures in parallel: Using both direct and indirect 
measures produces the most effective and efficient way to tackle undeclared work. A holistic 
approach  is  both  strategic  and  coordinated,  using  a  combination  of  direct  (e.g.  workplace 
inspections  and  peer-to-peer  surveillance)  and  indirect  (e.g.  awareness  raising  campaigns 
and  educational  initiatives)  approaches,  to  help  transform  undeclared  work  into  declared 
work.  

According  to  the  respondents  to  the  2019  survey,  the  Platform  should  in  the  future  focus 
more on awareness raising and trust-building initiatives (65% of respondents), incentives to 

7 

 
 
 
 
 
operate  on  a  declared  basis19  (55%)  and  operations  at  the  cross-border  level  (55%). 
Respondents do not see a need for major changes in activities. The focus still should be on 
events bringing members together to exchange practices in seminars (74%), thematic review 
workshops  (65%),  working  groups  (61%)  and  staff  learning  visits  (52%).  Sharing  good 
practice fiches and success stories should be continued according to 48% of respondents. 

3.  PROGRESS ACHIEVED TOWARDS ACHIEVING THE PLATFORM'S OBJECTIVES  

This section examines progress towards the Platform’s objectives under Article 4 of the 
Decision.   

Platform achievements: an overview 

3.1.  Enhancing  cooperation  between  Member  States’  relevant  authorities  and 
other relevant actors in order to tackle undeclared work more efficiently and 
effectively 

Building a multi-faced network 

The Platform has brought together over 50 stakeholders into a unique network, in a context 
where responsibility for tackling undeclared work is typically spread across different bodies 
and social partner involvement, uneven.  Prior to the Platform, instances of cooperation at EU 
level were few and mostly ad hoc (e.g. through the Senior Labour Inspectors Committee, the 
Expert  Committee  on  Posting  of  Workers,  and  the  Employment  Committee,  which  do  not 
primarily  focus  on  combatting  undeclared  work),  with  little  knowledge  exchange  and 
cooperation.  

The  Platform  has  widened  existing  networks  and  strengthened  cooperation  in  tackling 
undeclared work, both within countries and across borders. Almost all respondents (94%) to 
the  2019  survey  indicated  that  its  activities  contributed  to  widening  their  organizations’ 
networks and contacts. Most (68%) share the view that the Platform has also contributed to 
enhancing cooperation between Member States’ relevant authorities and other relevant actors.  

19 Such incentives cover a large range of measures including, for instance, advisory inspections, formalisation services and 
targeted VAT reduction in sectors at risk.  

8 

 
 
 
 
                                                           
Members and observers  have been  generally active, with  all having taken part in  activities.  
However,  there  have  been  varying  levels  of  commitment  and  participation  in  the  Platform 
between  countries.  The  network  is  still  maturing  and  there  is  much  untapped  potential  for 
members and observers, including social partners, to fully engage, and better disseminate the 
learning to achieve wider buy-in and impact.  

Developing a consensus on effective policy approaches 

When the Platform initiated its work, Member States were at very different starting points in 
terms of the level and nature of their overall approach, organisational capacity and the extent 
to  which  undeclared  work  was  perceived  as  a  priority.  The  Platform  has  since  helped 
determine the fight against undeclared work as priority action and forge a consensus on 
effective  policy  approaches.  Through  cooperation  with  peers  and  in  particular  Mutual 
Assistance, Platform members have received direct support in designing and delivering such 
approaches.  

Members’  feedback  suggests  that  the  Platform  has  contributed,  in  particular,  to  the 
development of a more holistic approach to tackling undeclared work. Beyond a strong 
emphasis  on  information  and  awareness-raising,  it  has  also  encouraged  a  shift  towards 
transforming  undeclared  into  declared  work  through  more  effective  deterrence  approaches 
such as inspections and sanctions, underpinned by risk assessment and better data exchange. 
Platform members indicated that their country or organisation made or are planning to make 
changes  (for  instance  in  policy  frameworks  and  implementation  measures)  as  a  result  of 
involvement  in  Platform  activities,  in  relation  to:  awareness  raising  and  trust-building 
initiatives  (52%),  deterrence  and  detection  measures  (39%),  operations  at  the  cross-border 
level  (32%),  incentives  to  operate  on  a  declared  basis  (23%),  organisational  models  (16%) 
and wider structural reforms (16%).  

However, in terms of approaches to fight undeclared work, the Platform’s emphasis has been 
primarily  on  tackling  labour  law  violations,  rather  than  tax  and  social  security  non-
compliance, reflecting the composition of its membership. Besides, the limited evidence-base 
to build upon also hampered further progress in this area. 

Towards a more holistic approach  

Consensus  amongst  Platform  members  and  observers  has  emerged  that  a  ‘holistic 
approach’ is required to tackle undeclared work  at the policy and operational level, using 
the  full  range  of  policy  measures  available  and  cooperation  across  key  bodies  and  with 
social partners.  

The  2019  Platform  survey  highlighted  major  improvements  in  this  regard,  with  new 
national coordinating bodies set up in France, Lithuania and Romania and a national pilot 
in Finland20, and more comprehensive range of measures and/or new strategies in France, 
Greece, and Latvia.  

20 The national pilot on work-related crime included OSH, tax and police authorities to cooperate in a more strategic way in joint actions and 
cooperation projects. 

9 

 
 
 
                                                           
3.2.  Improving the capacity of Member States’ relevant authorities and actors to 

tackle undeclared work with regard to cross-border aspects 

Specific  types  of  cross-border  undeclared  work,  for  instance  by  undeclared  mobile  EU 
workers or related to fraudulent posting of workers - including through letterbox companies - 
require broader and better cross-border cooperation. Cooperation channels currently typically 
range  from  information  and  staff  exchange  to  joint  inspections,  underpinned  by  bilateral 
agreements and memorandums of understanding.  

Joint Nordic undeclared work project 

Supported by EU funding under the EU Programme for Employment and Social Innovation 
(EaSI),  Denmark,  Estonia,  Finland,  Iceland,  Latvia,  Norway  and  Sweden  have  joined 
forces to cooperate in a joint Nordic undeclared work project. The project focuses on joint 
inspections,  sharing  good  practices  (particularly  on  communication  and  preventative 
approaches)  and  evaluating  results.  It  aims  at  better  equipping  the  Nordic  countries  to 
tackle  undeclared  work  through  information  sharing,  collaboration,  possibilities  for 
assistance, and knowledge sharing.   

The Platform has helped Member States step up partnerships in tackling cross-border 
undeclared  work,  paving  the  way  for  further  cooperation  under  the  European  Labour 
Authority.  Thanks  to  increasing  mutual  trust  and  regular  contacts,  Members  States  have 
consolidated  existing  partnerships  and  engaged  with  new  countries.  Besides,  the  work 
programme  has  put  an  increasing  focus  on  cross-border  aspects  and  delivered  tools 
supporting  them  improve  their  practices  through  studies  (e.g.  on  cross-border  cooperation), 
working groups (on data exchange) and thematic review workshops and toolkits (on bilateral 
agreements and memorandums of Understanding, Joint and Concerted Inspections).  

However, the level of engagement in cross-border cooperation remains uneven. National 
authorities  predominantly  focus  on  ad  hoc  cooperation  with  neighbouring  countries, 
responding to immediate challenges rather a strategic plan. Most labour inspectorates rarely 
engage in concerted and joint cross-border inspections (1-2 times annually)21. Cooperation in 
the context of the European Labour Authority, including with social partners’ organisations, 
could  allow  addressing  some  of  these  challenges  and  overcome  the  Platform’s  limited 
operational capacity.  

Surge in cross-border collaboration and progress on improving capacity 

In the 2019 survey, 61% of respondents stated that the Platform contributed to improving the 
capacity of Member States' relevant actors to tackle undeclared work with regard to its cross-
border  aspects.  Organisations  undertook  or  plan  to  engage  in  cross-border  activities  in  the 
next year, including: cross-border meetings of officials (52%), staff exchanges / joint actions 
(41%), joint inspections (39%).  

21 Stefanov R., Mineva D., Terziev P. (2019). Cross-border actions tackling undeclared work. European Platform tackling 
undeclared work: Brussels 

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3.3.  Increasing  public  awareness  of  issues  relating  to  undeclared  work  and 

encouraging Member States to step up their efforts   

The  Platform  has  contributed  to  a  stronger  emphasis  on  awareness  raising  among  its 
membership,  with  half  of  the  members  reporting  changes  in  this  area.  Work  has  focused 
primarily  on  encouraging  members  to  share  their  learning  on  awareness-raising  campaigns 
through  specific  activities  (e.g.  thematic  review  workshop  and  a  toolkit22,  seminars  on 
preventative approaches and dissemination of Platform activities).  

However, direct impact in increasing public awareness has been slower to develop. Only 
35%  respondents  to  the  2019  survey  agree  the  Platform  made  very  good  or  good  progress 
towards this objective. Recognising the need to translate this into action, the 2019-2020 work 
programme had a stronger focus on communication and awareness-raising. The first Platform 
campaign  on  the  benefits  of  declared  work,  developed  by  members  and  observers,  will  run 
from March to June 2020. It will be underpinned by a week of action calling on members to 
join up their efforts.  

4.  CONCLUSIONS  

Since its start in 2016, the European Platform tackling undeclared work has facilitated greater 
cooperation between and across countries. Building on a strong governance, comprehensive 
work programme and active involvement of members, it has contributed to efficiency gains 
and the modernisation of enforcement bodies across the EU. It has produced solid evidence-
based  knowledge  enabling  Member  States  and  social  partners  to  learn  from  each  other, 
innovate and act together.  

As  regards  remaining  challenges,  the  Platform’s  activities  have  highlighted  the  need  to 
enhance  the  commitment  from  all  members  and  to  increase  the  Platform’s  operational 
capacity. Enforcement bodies and social partners need to continue to develop more effective 
cooperation,  both  at  national  level  and  cross-border,  by  further  developing  strategic  and 
operational  approaches  towards  tackling  undeclared  work.  There  is  much  potential  for 
deepening mutual learning between Member State authorities and improving effectiveness of 
measures tackling undeclared work in particular through better data sharing, data analysis and 
risk  assessment,  as  well  as  through  better  cross-border  cooperation.  In  part,  such 
improvements  can  be  achieved  by  further  developing  EU-level  information  systems,  which 
would be used not only for identifying high risk businesses for inspection purposes but also 
for  better  targeting  preventative  approaches.  Further  developing  synergies  with  key  EU 
initiatives  and  policies  (for  instance  those  related  to  the  labour  conditions  of  platform 
workers,  the  European  Semester  and  the  implementation  of  the  European  Pillar  of  Social 
Rights,  exchange  of  information  for  tax  purposes  including  employment  income23)  and 
funding instruments (such as the European Social Fund +) is also essential in this regard. It is 
important  to  further  develop  a  comprehensive  approach  which  combines  efficient  and 
effective  deterrence  measures  with  measures  aimed  at  preventing  undeclared  work  from 
occurring in the first place. Further emphasis can also be put in the future on education and 
awareness-raising  with  citizens,  workers  and  employers  about  their  rights,  responsibilities 
and  obligations.  #EU4FairWork,  the  first  Platform  information  and  awareness-raising 

22 Information tools and approaches to reach out to employers and workers in the fight against undeclared work 
https://ec.europa.eu/social/BlobServlet?docId=20864&langId=en 
23 Directive on Administrative Cooperation in the field of taxation, Council Directive 2011/16/EU of 15 February 2011 

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campaign,  running  between  March  and  June  2020,  is  an  important  step  in  this  direction, 
which will need to be built upon.  

The  cooperation  of  Member  States  within  the  European  Labour  Authority  can  build  on  the 
high  levels  of  trust  and  well-established  cooperation  between  Platform  members  and 
observers.  This  will  provide  a  solid  basis  for  better  cross-border  cooperation  and  capacity 
building in the initial phase of the ELA, which has a much broader mandate. The wider scope 
of  ELA  will  compensate  for  the  Platform’s  more  limited  operational  capacity  and  uneven 
involvement within its membership. 

The Platform's 2019-2020 work programme will be implemented as planned, allowing for a 
smooth  transition.  Decision(EU)  2016/344  will  be  repealed  once  the  ELA  has  reached  full 
operational capacity, however the Platform’s current objectives, missions and activities have 
been  largely  confirmed  in  the  Regulation  establishing  the  ELA  (Article  12  and  Annex)  24. 
Besides,  the  establishment  of  the  ELA  provides  the  opportunity  for  further  change  and 
addressing the challenges emerging from the Platform’s initial configuration.   

The European Labour Authority will set priorities and propose how to address the challenges 
highlighted  above  in  the  long  run.  It  can  be  envisaged  that  the  Platform,  as  a  permanent 
working  group  of  ELA,  focuses  on  its  core  task  of  tackling  undeclared  work  while  certain 
more  horizontal  tasks  such  as  support  to  operational  cross-border  cooperation,  capacity 
building  in  enforcement  bodies  and  developing  EU-wide  tools  can  be  more  coherently 
addressed  by  wider  ELA  activities.  The  Platform  will  benefit  from  a  comprehensive 
operational  structure  within  ELA  and  from  specialised  staff  expertise  in  different  areas. 
Because  of  synergies  with  other  ELA  activities  and  a  strong  mandate  to  tackle  undeclared 
work, the activities run by the Platform can be scaled up, refined, targeted and planned over a 
longer  timeframe.  The  participation  of  ELA  in  the  Platform  campaign  on  the  benefits  of 
declared work in 202025 is a good example for the synergies and the alignment of EU-level 
initiatives to support fairness on the European labour market.  

The establishment of the ELA will provide increased impetus to tackle undeclared work more 
effectively and transform it into declared work, contributing to fair working conditions, fair 
competition and fair mobility for the benefits of workers, the economy and society at large.  

24 Regulation (EU) 2019/1149 of the European Parliament and of the Council of 20 June 2019 establishing a European 
Labour Authority, amending Regulations (EC) No 883/2004, (EU) No 492/2011, and (EU) 2016/589 and repealing Decision 
(EU) 2016/344 
25 European Labour Authority, Work Programme 2020, https://ela.europa.eu/documents/ELA_Work_Programme_2020.pdf  

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