This paper examines the implementation of the directives on the transfer of undertakings, in whole or in part, with particular regard to the impact of individual workers’ rights of legislative provisions in Italy, the UK, Germany and France. A further consideration is that of information and consultation rights of workers in the event of a transfer, and EU provisions in the case of insolvency. Reference is made to a number of landmark rulings of the European Court of Justice, and it is argued that in this matter there is a considerable degree of convergence between the various national systems.
International Journal of Comparative Labour Law and Industrial Relations