Skip to main content

New obligations on short-term contracts could burden local employers 


As the European Commission considers revising the Written Statement Directive (91/533/EEC) to reflect the European Pillar of Social Rights, the Council of European Municipalities and Regions (CEMR) calls for a balanced and flexible approach that takes into account the realities of local and regional government employment. 

In its official response to the Commission’s first-phase consultation of the social partners, CEMR acknowledges that the Commission has correctly identified many relevant issues. However, it expresses concern that expanding the scope of the directive, particularly to cover all atypical and short-term work contracts, could result in disproportionate administrative burdens for local authorities. 

“The introduction of written statements for contracts under one month or eight hours would place a burden on employers that is not proportionate to the benefits for employees,” the response notes. 

CEMR stresses that: 

  • Most local government staff already fall under the existing rules; 
  • Local authorities need flexibility in handling casual and supply contracts, especially in sectors like education; 
  • Contractual elements should remain a matter for national decision-making, not EU regulation; 
  • There is a risk in conflating very different work arrangements, such as traineeships, digital platform work, and genuine self-employment. 

While supportive of fair and transparent working conditions, CEMR does not currently support new EU-level legislation in the areas identified and advises further analysis of the impact on public employers. Should EU-level social partners initiate negotiations under Article 155 TFEU, CEMR affirms its willingness to support the process. 

Read the position paper here 

For more information, contact: