For Information : ETUC Position on the e-Declaration on Posting

Brussels, 12 March 2025

• To the Social Attachés in the Permanent Representations of Member States to the EU

Dear Madam, Dear Sir,

On behalf of the European Trade Union Confederation (ETUC), we wish to share with you our Position on the e-Declaration on Posting, as adopted by our Executive Committee on 4-5 March 2025.

EN: ETUC Position on the e-Declaration on Posting
FR: Position de la CES sur la déclaration électronique de détachement

The ETUC has identified a number of concerns linked to the purpose and process of the 13 November 2024 proposal of the European Commission for a Regulation on a public interface connected to the Internal Market Information System for the declaration of posting of workers. Our concerns in particular relate to shortcomings in terms of enforcement potential and the possibilities of Member States to tailor the common form to their enforcement needs, systems and practices at national level in accordance with the margin of manoeuvre afforded by the Posting Enforcement Directive 2014/67/EU.

We thank you for your consideration, and remain at your disposal. For  any questions, please do not hesitate to contact ETUC Legal Advisor Joakim Smedman ([email protected]).

Yours sincerely,

Isabelle Schömann
ETUC Deputy General Secretary