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The EU Pay Transparency Directive’s transposition deadline—June 7, 2026—has passed. As of the June 7 deadline, only a handful of Member States—notably Slovakia, Italy and Lithuania—have fully or largely implemented the Directive, with most others still working through draft legislation or delayed timelines.

Most member states are behind, resulting in uneven implementation across the bloc and leaving employers to navigate a fragmented and evolving landscape with staggered national rollouts and divergent approaches across jurisdictions. Here’s what US-based multinationals need to know now.

The Practical Outlook for Multinational Employers

For US companies managing EU workforces, the next 12–24 months will look like:

Patchwork Implementation

  • Countries will finalize laws on different timelines
  • Some will gold-plate requirements (e.g., broader scope, stricter remedies)
  • Others may take a more minimalist approach

Rolling Compliance Programs

  • Employers will need to sequence implementation by jurisdiction
  • Internal frameworks must be modular and adaptable, not one-size-fits-all

Heightened Litigation & Enforcement Risk

Even before full implementation, expect:

  • Increased employee claims and works council pressure
  • Greater scrutiny of pay equity and transparency practices
  • Use of existing laws (e.g., equal pay frameworks) alongside emerging rules

Reminder of the Directive’s Core Requirements

The Directive introduces a consistent set of core obligations across the employment lifecycle, centered on greater transparency, more rigorous pay monitoring, and enhanced enforcement risk—though the detail and delivery will vary by country.

Continue Reading EU Pay Transparency Directive: Deadlines Missed, But the Real Work Starts Now

As sweeping reforms converge to redefine workplace standards, employer responsibilities and employee rights, 2026 will require global businesses to balance rapidly evolving workplace regulation with the need to safeguard commercial interests.

Global regulation shifts in focus

Across the UK, the Americas and Europe, three key themes dominate: equity, openness and flexibility.

In the UK, the recent Employment Rights Act will broaden protection against unfair dismissal by reducing the qualifying period from two years to six months and removing the existing caps on compensation. These changes are anticipated from January 2027. The act will create other significant changes in 2026 and into 2027, including measures strengthening union influence; broadened thresholds for collective consultation and increased associated penalties for breaches; severe restrictions on imposing contractual variations, improved job security for zero- and low-hours workers; and broadened protections against harassment. In short, there will be a seismic shift to the compliance landscape. Employers will need to stay alert, as many of the finer details remain unknown.

The European Union is taking a proactive approach to strengthen its global competitiveness, aiming to boost innovation and economic growth. However, core worker protections are likely to remain strong with employers facing a wave of new regulation including the Pay Transparency Directive, the AI Act, and a revised framework for European Works Councils. Meanwhile, the Quality Jobs Roadmap forms part of the EU’s strategy to generate and maintain sustainable, high-quality employment. This potentially includes legislative measures to safeguard workers’ rights while adapting to ongoing technological, economic, and societal developments.

Recent employment law developments across Asia Pacific and Latin America also reflect a strong focus on worker protection, flexibility and fairness. Wage reforms are prominent, with South Korea and multiple Philippine regions announcing significant minimum wage increases, while Malaysia’s Gig Workers Bill enhances rights and security for nontraditional workers. Broader labor rights are evolving through measures like South Korea’s Yellow Envelope Act, which expands union protections, while Singapore’s Workplace Fairness Act seeks to ensure fair treatment for employees, including by providing greater protection against workplace discrimination. In Latin America, labor reforms are continuing, with Brazil seeking to strengthen equal pay compliance, Colombia modernizing its labor inspection regime, Mexico proposing reforms to strengthen workers’ rights and Argentina seeking to introduce sweeping changes to modernize labor relations while fostering competitiveness.

Overall, these changes underscore a regional trend toward safeguarding employee well-being, regulating digital work environments and ensuring equitable treatment across diverse employment models.

Continue Reading A Year of Workforce Transformation Prioritizing Fairness

We recently recorded a lively discussion with several of our Baker McKenzie colleagues to discuss the major developments impacting multinational employers operating in Europe. For your convenience, click here for a link to the recording.

To preview some of the key changes our team highlighted, read on!

The socio-political climate across Europe is contributing to…

As AI adoption accelerates across workplaces, labor organizations around the world are beginning to take notice—and action. The current regulatory focus in the US centers on state-specific laws like those in California, Illinois, Colorado and New York City, but the labor implications of AI are quickly becoming a front-line issue for unions, potentially signaling a new wave of collective bargaining considerations. Similarly, in Europe the deployment of certain AI tools within the organization may trigger information, consultation, and—in some European countries—negotiation obligations. AI tools may only be introduced once the process is completed.

This marks an important inflection point for employers: engaging with employee representatives on AI strategy early can help anticipate employee concerns and reduce friction as new technologies are adopted. Here, we explore how AI is emerging as a key topic in labor relations in the US and Europe and offer practical guidance for employers navigating the evolving intersection of AI, employment law, and collective engagement.

Efforts in the US to Regulate AI’s Impact on Workers

There is no specific US federal law regulating AI in the workplace. An emerging patchwork of state and local legislation (e.g. in Colorado, Illinois and New York City) address the potential for bias and discrimination in AI-based tools—but do not focus on preventing displacement of employees. In March, New York became the first state to require businesses to disclose AI-related mass layoffs, indicating a growing expectation that employers are transparent about AI’s impact on workers.[1]

Some unions have begun negotiating their own safeguards to address growing concerns about the impact that AI may have on union jobs. For example, in 2023, the Las Vegas Culinary Workers negotiated a collective bargaining agreement with major casinos requiring that the union be provided advance notice, and the opportunity to bargain over, AI implementation. The CBA also provides workers displaced by AI with severance pay, continued benefits, and recall rights.

Similarly, in 2023 both the Writers Guild of America (WGA) and Screen Actors Guild-American Federation of Television and Radio Artists (SAG-AFTRA) negotiated agreements with the Alliance of Motion Picture and Television Producers (AMPTP) that include safeguards against AI reducing or replacing writers and actors. WGA’s contract requires studios to meet semi-annually with the union to discuss current and future uses of generative AI—giving writers a formal channel to influence how AI is deployed in their industry. The SAG-AFTRA contract requires consent and compensation for use of digital replicas powered by AI.

Continue Reading Navigating Labor’s Response to AI: Proactive Strategies for Multinational Employers Across the Atlantic

Tune into our annual Global Employment Law webinar series as we bring the world to you.

Our Global Employment Law Fastpass webinar series is here again! Every June, we offer four regionally-focused webinars to help you stay up-to-speed on the latest employment law developments around the world. From tariffs and economic uncertainty to the use…

Here’s your go-to guide for annual filing and reporting requirements for global employee share plans.

It is almost the end of the calendar year and time for multinational companies to consider the necessary tax and regulatory filings for global share plans triggered by the close of 2024 (or by the end of a local…

In June, we offered our annual Global Employment Law webinar series sharing expert insights on the business climate in major markets around the world for US multinational employers. Baker McKenzie attorneys from over 20 jurisdictions outlined the key new employment law developments and trends that multinationals need to know in four 60-minute sessions.

ICYMI: click below to hear updates for the Americas, Asia Pacific, Europe and the Middle East and Africa and contact a member of our team for a deeper dive on any of the information discussed.

Session 1: The Americas 

Presenters: Andrew Shaw, Clarissa Lehmen*, Daniela Liévano Bahamón, Benjamin Ho, Liliana Hernandez-Salgado and Matías Gabriel Herrero

Click here to watch the video.

*Trench Rossi Watanabe and Baker McKenzie have executed a strategic cooperation agreement for consulting on foreign law.

Continue Reading Summer Replay: Tune In To Our Global Employment Law Update Series (Recordings Linked!)

We’re bringing the world to you. Join Baker McKenzie for our annual Global Employment Law webinar series.

In the face of intensifying geopolitical risk and continuing economic uncertainty, the challenges for global employers to plan carefully and operate strategically to maintain a thriving workforce is greater than ever. We’ll help employers navigate those challenges in…

Special thanks to co-authors Glenn Fox and Paul DePasquale.

One of the biggest sleeper issues (in my opinion) for US companies when granting equity awards to non-US employees or other service providers is the fact that their heirs may be assessed with US estate tax and be required to file an estate tax return in the US if the individual dies while holding equity awards or shares.

US Estate Tax Exemptions

Individual US taxpayers (i.e., US citizens and non-US citizens who are domiciled in the US) can currently benefit from a significant estate tax exemption: no estate tax is due unless the value of the estate exceeds US$13,610,000 (this is the inflation-adjusted amount for 2024), reduced for taxable lifetime gifts, but doubled for married couples if both spouses’ estates qualify for the exemption. Accordingly, relatively few US estates currently are subject to estate tax. In any event, US employees and their heirs will most likely be well aware of possible estate tax consequences for their assets, including equity awards and shares acquired under a company share plan.

Continue Reading A Cautionary Tale: US Estate Tax May be Due on Equity Awards/Shares Held by Non-US Residents

With thanks to Mirjam de Blécourt and Danielle Pinedo for this update.

On June 12, after lengthy negotiations, the EU Council agreed on the proposal for a directive that aims to better protect platform workers. This opens the door to negotiations between the Council and the European Parliament on the final directive.

The directive aims to ensure that platform workers have or can obtain the appropriate employment status through the introduction of a legal presumption. In addition, the directive provides for rules regarding the transparency of the use of algorithms within the platform economy.

Continue Reading The European Council Takes on Misclassification of Platform Workers