Industrial relations: Discourse on and developments in working time arrangements in 2025

Social dialogue and collective bargaining continued to shape working time arrangements across Europe in 2025. Two rulings by the Court of Justice of the European Union (CJEU) on the topic of working time arrangements came into effect, impacting the related discourse at national level. The outcomes of national-level discussions involving the social partners were uneven. Concrete results were achieved through legislation or collective agreements in some countries, while, in others, the social partners debated working time issues without reaching any agreement.

CJEU rulings, which are binding on national courts, continue to clarify how EU labour law must be applied. The topics covered by two rulings in 2024 – working time recording and overtime – featured prominently in discussions between governments and social partners in many Member States in 2025, indicating that both remain firmly on the agenda at national level.

Recording the working time of domestic workers

Case C-531/23 HJ v US and MUopens in new tab (the Loredas case) is about whether EU Member States can exempt private households from the obligation to record the working hours of domestic workers, such as au pairs. On 19 December 2024, the CJEU ruled that such exemption is not allowed under EU law, which requires all employers to have an objective and reliable system for recording working time. This is to allow employees to exercise their rights regarding maximum weekly working hours and minimum rest periods. How this ruling will influence time-recording practices in the Member States remains to be seen. In the meantime, governments in several Member States have addressed the subject of recording working time without necessarily making reference to the CJEU decision in Loredas. In Spain, the Council of Ministers presented a draft law in 2025opens in new tab based on an agreement reached in 2024 between the two main trade unions – Workers’ Commissions (CCOO) and the General Union of Workers (UGT) – and including provisions on time recording. However, the proposals were not supported by the employer confederations – Spanish Confederation of Employers’ Organisations (CEOE) and Spanish Confederation of Small and Medium-sized Enterprises (CEPYME). The draft law was ultimately not passed, owing to a lack of parliamentary support.

In Greece, Law 4808/2021 requires all companies to establish an electronic system for recording working hours (the ‘digital work card system’), with the aim of preventing undeclared or underdeclared employment. The digital work card system had already been introduced in 2021 in certain sectors and was extended to new sectorsPDFopens in new tab in 2025 by Law 5239/2025.

These cases illustrate two different approaches to the implementation of time-recording regulations. Spain tried to pass new obligations into law but the attempt stalled, owing to lack of employer and parliamentary support. In contrast, Greece, rather than creating a new system of time recording from scratch, extended the reach of a tool that was already in place. Thus, the examples show how pre-existing arrangements and infrastructure may shape the discourse and implementation surrounding time recording.

Earlier CJEU rulings on time recording

Loredas was not the first case in which the topic of time recording was brought up in the context of improving working conditions. In 2019, Case C-55/18 CCOO v Deutsche Bankopens in new tab examined whether EU law requires employers to keep a daily record of the actual working hours of their employees. The CJEU ruled at the time that all Member States must require employers to establish an objective, reliable and accessible system for recording the daily working hours of every employee. 

Compliance with this ruling varies across Member States, however. In Germany, for example, the Education and Science Union (GEW), during the 30th Trade Union Congress in 2025, highlighted that the country had not yet fully implemented the ruling. The GEW argued that working conditions needed to be improved to make the teaching profession more attractive to young people. This example reflects a broader issue with CJEU court rulings, i.e. that their implementation in practice is often lagging – something that could also occur in the case of the Loredas ruling.

Discrimination in overtime pay for part-time employees

Another 2024 CJEU ruling that impacted labour law frameworks across the EU and became a hot topic for discussion in 2025 was that issued in Joined Cases C-184/22 and C-185/22 IK and CM v KfH Kuratorium für Dialyse und Nierentransplantation e.V.opens in new tab (the KfH case). This ruling concerns overtime pay for part-time employees and whether the current calculation method can result in unlawful discrimination. Under the collective agreement cited in the ruling, part-time employees only received overtime pay once their working hours exceeded the full-time limit, not the hours agreed upon in their contract. For example, an employee contracted for 20 hours per week who worked 30 hours would not receive any overtime pay, because 30 hours is below the full-time threshold of 40 hours. The CJEU ruled that granting overtime pay to part-time employees only once they have exceeded the threshold for full-time employment is unlawful under EU law.

In Norway, this ruling prompted a discussion regarding whether regulatory changes need to be made to the country’s wage-setting system. Part-time workers in Norway only become entitled to overtime pay once they have exceeded the standard weekly working-hours threshold for a full-time employee. This is similar to KfH. A change whereby additional hours worked would be remunerated as overtime could significantly alter the country’s wage-setting system. Payment for additional hours is regulated through collective agreements in Norway, so any change would also require amendments to these agreements. In response to this, the government set up a tripartite working group in 2025 whose tasks include proposing regulatory changes (in compliance with EEA law) to prevent discrimination between part-time and full-time employees with regard to payment for overtime. At the time of writing, the group had not managed to reach consensus on common solutions or proposals for regulatory changesopens in new tab.

One country where the CJEU ruling has already had a direct effect on its wage-setting system is the Netherlands. Here, it led to the Ministry of Social Affairs and Employment urging the parties involved in negotiating collective labour agreements (CAOs) – employers and trade unions – to critically review their agreementsopens in new tab to ensure they align with EU law. The Ministry warned that if CAO overtime provisions distinguish between part-time and full-time workers based on working hours, without an objective justification, employers will be at risk of violating equal-treatment norms.

The extent to which this ruling will reshape overtime practices across Europe remains to be seen. The country examples illustrate how the same ruling can prompt different responses, depending on existing wage systems and collective bargaining structures.

In 2025, reducing standard working hours without a commensurate cut in wages was, as in the previous two years, among the most prominent issues in collective-bargaining and social dialogue across the EU. Developments in this area ranged from cross-industry and sectoral agreements setting new thresholds for weekly hours to company-level pilots of four-day-working-week models. While some initiatives resulted in binding agreements, others remained at the proposal or pilot stages.

Cross-industry initiatives

Working time reduction at cross-industry or national levels has historically been an area in which social dialogue has played a significant role, contributing to changes in the industrial relations landscape of various countries. Although the 40-hour working week is the standard in most countries, cross-industry collective bargaining and social dialogue are used to lower the standard number of hours.

In 2025, several attempts were made by social partners to advance cross-industry working time reduction. In Spain, for example, a cross-industry social dialogue contract with the trade union organisations CCOO and UGT and the Ministry of Labour proposed reducing working hours to 37.5 per week. However, the employer confederations CEOE and CEPYME did not support the agreement, and the measure was not passed into legislation owing to lack of parliamentary support.

Similarly, in Sweden, working time reduction became a prominent topic in social dialogue as part of a broader employer–union discussion on work–life balance and labour costs. The trade union confederation LO has been advocating for a cross-industry reduction in working timeopens in new tab, while, in October 2025, the Swedish employer organisation Almega published a discussion article opposing broad, centrally mandated working time reductions, arguing that such measures would be devastating for business margins, competitiveness and the autonomous collective bargaining model in the Swedish labour market.

Malta is another country in which social partners have pushed for working time reduction at cross-industry level. Several trade unions argued in their pre-budget documents that Malta should move towards or test a shorter working week without a loss of pay. However, the introduction of a four-day week was opposed by employer organisations and ultimately ruled out by the government on the ground of how much it would cost the Maltese economyopens in new tab.

Other countries took the legislative route, introducing new laws or programmes that affect working time arrangements either directly or indirectly. In Poland, the Ministry of Family, Labour and Social Policy participants in launched a pilot programmeopens in new tab to test a shorter working week, whereby the number of weekly hours would be reduced from 40 to 35 without any loss of wages. The programme is designed to promote a bottom-up and flexible framework, so that participants can choose their own model, such as a four-day week or shorter daily hours. The preparatory Phase I ran until the end of 2025, while Phase II is scheduled to last for the whole of 2026. Participation is co-financed by the Ministry of Family, Labour and Social Policy (averaging approximately PLN 0.5 million (€114,500) per employer) and entails a commitment to ensure working conditions or wages do not deteriorate during the experiment.

These cases point to different outcomes of attempts to reduce working hours at cross-industry level. Although, the Spanish initiative had support from both the government and trade unions, it was not backed by parliament or employers. In Sweden and Malta, the lack of agreement was due to pushback from employer organisations. Poland adopted a voluntary system funded partially by the state, rather than pursuing a binding reduction at cross-industry level. These examples suggest that mandatory, uniform approaches to working time reduction may find it more difficult to attract support than more flexible and voluntary models.

Sector-level initiatives

While there were no significant developments in working time reduction in any Member State as a result of cross-industry collective bargaining or social dialogue, some progress was made thanks to sector-level agreements.

In Finland, the IT Service Sector Collective AgreementPDFopens in new tab (2025–2027) sets standard daytime work at 7.5 hours a day (37.5 hours a week). However, companies can locally agree to an eight-hour workday if they give employees paid days off to keep the long-term weekly average at 37.5 hours. Similarly, in Slovakia, multi-employer collective agreements were signed for state employees and employees in public service covering the period from 1 July 2025 to 31 December 2025. These agreements were negotiated between representatives of the government, employer associations and trade unions. Key working time and work–life balance provisions include shortened weekly working time (37.5 hours instead of the standard 40) and extended holiday entitlement for employees over the age of 33.

In Spain, different sector-level agreements signed in 2025 introduced a reduction in working hours. For example, the chemical industry agreement, covering around 300,000 employees, sets maximum annual working hours at 1,752 for 2024–2025, dropping to 1,744 from 2026. There are also examples of sector-level collective agreements at regional level in Spain that have reduced working hours. For example, in Andalucia, a collective agreement in the sports services sectoropens in new tab, signed between the Spanish Association of Sports Services Companies for Public Administrations (AEESDAP) and the Federation of Citizen Services (FSC) on 31 July, included clauses relating to working time reduction. Under these clauses, the standard working week is reduced to 37.5 hours in 2026 and to 37 hours from 2028 onwards.

There have also been collective agreements on reducing annual working hours at sector level in Sweden. In 2025, TechSverige (the employer organisation in the Swedish tech industry) concluded new collective agreementsopens in new tab for the IT and tech sectors with unions including Unionen, Sveriges Ingenjörer and Akavia. These agreements include a negotiated reduction in working hours equivalent to one paid day off per year (introduced from 2026) as part of the overall package, alongside wage increases and other terms.

These sector-level cases illustrate two ways of reducing working hours. In Finland, Slovakia and Spain, agreements were reached on lowering weekly working hours. Sweden chose a different approach, leaving the standard working week as it was and, instead, converting the equivalent value of a reduction in weekly working time into paid time off or additional rest days.

Company-level initiatives

In 2025, social dialogue and collective bargaining at company level resulted in a reduction of working hours in several Member States. For example, in Spain, the new collective agreement for workers at the Municipality of Barcelona for 2025–2028opens in new tab, agreed in December 2025, included a reduction of weekly working hours from 37.5 hours to 35 hours.

Furthermore, some companies have opted in their collective agreements for a four-day working week instead of a general reduction in working-week hours. For example, in Italy, EssilorLuxottica signed an agreement with trade unionsopens in new tab FILCTEM CGIL, FEMCA CISL and UILTEC to extend its four-day working-week model. This model was due to be piloted across the ophthalmic equipment specialist’s production site from 1 January 2026, with all personnel benefiting from 20 weeks of 4 working days (Fridays off) without a reduction in salary.

These examples illustrate that working time reduction continues to be pursued through social dialogue and collective bargaining at company level and can take the form of a general reduction in weekly hours or a shift towards a four-day working week.

Summary – working time reduction

Developments in the area of working time reduction across the EU in 2025 reflect the diversity of national industrial relations systems and the levels at which social dialogue takes place. At cross-industry level, several proposals were discussed by the social partners but did not always translate into binding outcomes. At sector and company levels, several agreements were concluded that reduced weekly working hours or introduced similar arrangements that would have the same outcome. These developments illustrate the continued relevance of social dialogue in shaping working time arrangements across the EU.

EU regulations guarantee at least 20 days of paid annual leave for all workers. Above this floor, the number of leave days can vary between Member States. Most Member States stick with the 20-day minimum annual leave, but a small number have implemented laws that guarantee higher legal entitlements, ranging from 22 to 26 days. While the statutory rules determine the baseline of annual leave, the actual amount of paid annual leave is often higher, since, in many sectors and companies, extra days are negotiated through collective agreements. In countries such as Spain, France and Germany, the actual number of paid annual leave days tends to be around 30.

Improvements to annual leave entitlements were a recurring feature of collective bargaining in 2025. Agreements at various levels introduced additional leave days, new categories of special leave, and more flexible mechanisms for accumulating and using time off. These developments reflect a broader negotiating trend, whereby leave provisions are increasingly used as a tool to improve working conditions, alongside or instead of wage increases.

Sector-level initiatives

An example of where sector-level collective bargaining in 2025 resulted in additional annual leave is offered by Germany. The collective agreement for employees working for federal and municipal public employers now includes clauses relating to annual leave. All employees will receive an additional day of holiday from 1 January 2027, and they will be able to convert part of their annual bonus payment into three additional days of holiday.

Similarly, in Italy, the national collective labour agreement (CCNL) that sets mandatory sectoral standards for wages, working conditions and employee rights in the electricity sector was renewed for 2025–2027 by the main social partners. These included the trade unions Italian Federation of Chemical, Textile, Energy and Manufacturing Workers (FILCTEM CGIL), Federation of Italian Electrical Company Workers (FLAEI CISL) and Italian Union of Chemical, Energy, Manufacturing, Transport and Research Workers (UILTEC), as well as employer associations and major companies, such as Enel (the National Electricity Board), transmission system operator Terna, energy services operator GSE and nuclear decommissioning company Sogin. The agreement introduced key changes with regard to working time reduction, transforming three half-day afternoon allowances into three fully paid rest days.

Company-level initiatives

There were also company-level changes to annual leave in 2025 as a result of collective bargaining.

One such example comes from Spain, where a collective agreement was signed between the telecoms operator DIGI and trade unions CCOO and UGT.PDFopens in new tab The agreement covers around 8,000 employees and includes clauses increasing the number of leave hours for personal reasons by 10 hours to support work–life balance, as well as extending annual leave by two additional days. This agreement is particularly significant, as it unified working conditions within a large company that had previously been covered by different agreements across workplaces and by multiple regional collective agreements. Similarly, in Germany, postal service operator Deutsche Post agreed that the approximately 170,000 employees working for the company would receive an additional day of annual holiday from 1 January 2026.

In other countries, paid annual leave was increased via conditional clauses inserted into collective agreements. In Italy, banking group Intesa Sanpaolo signed a company-level collective agreementopens in new tab with trade unions granting additional paid leave for medical appointments and formalising the use of time banking to accumulate extra hours off. Similarly, in Germany, the United Services Union (ver.di) and railways company Deutsche Bahn agreed on a clause that will allow employees to convert part of their bonus payments into two additional days of leave.

Summary – annual leave

In 2025, collective bargaining continued to play a role in extending annual leave beyond the statutory minimum. At sector level, new collective agreements for workers in the municipal and public sector in Germany and for workers in the electricity sector in Italy introduced additional leave days or new ways to convert other benefits into time off. At company level, agreements at DIGI in Spain, Intesa Sanpaolo in Italy and Deutsche Bahn and Deutsche Post in Germany showed a similar pattern, with leave entitlements extended through direct increases or more flexible arrangements. Overall, these cases show that leave provisions is an area in which social partners continue to negotiate improvements for employees.