Abstract: This article argues that new legislation implementing the Framework Employment Directive prohibiting discrimination on grounds of religion, belief or sexual orientation will make no impact on employers? practices and behaviour, unless they are underpinned by enforcement mechanisms similar to those provided under the current anti-discrimination law. In this regard, the article explores the existing framework for enforcement of anti-discrimination law by existing equality bodies in the UK and in Germany and supports the proposals for the establishment of single Equality Commissions in both countries. The article states that the issues of enforcing the new grounds of anti-discrimination should be addressed before the new Commissions come into existence.
International Journal of Comparative Labour Law and Industrial Relations