S. Stiller (2019) Between incremental changes and large shifts > The development of employment institutions in five EU countries and the United States (1990 - 2016), AIAS Working Paper 7

This paper gives a comparative overview of employment institutions in six countries: the United States, the United Kingdom, Germany, the Netherlands, Hungary and Denmark. It investigates the direction of change in employment institutions and describes the underlying reasons for the changes and important issues influencing national labour markets during the past 25 years based on expert interviews and literature study. An overall comparison of the recent situation of employment institutions reveals, first, that the selected countries show relatively large variation on the protection of the individual and collective employment relationships and employment conditions. Most countries experienced different reform trajectories - in terms of timing and the nature of changes - on the aspects of work related to labour law (individual and collective employment relationship, employment conditions).  Second, in terms of reasons for the changes that occurred, there was one strong incentive for EU countries to adapt institutions in the same direction (except for the United States which continued on a course of minimal state invention in the sphere of employment). A prominent reason for varying directions of change across countries is related to governments’ policy agendas, which differ because of country-specific contextual factors including the perception of of problem pressures, the type of coalition government in place, and political and/or societal opposition to proposed changes. In some other aspects of work – e.g. labour market transitions - countries did follow roughly the same direction of change, for instance, as seen in the spread of the activation paradigm, albeit with country-specific gradations and variations in strictness on positive and negative incentives to get back into work. Third, as issues affecting labour markets in all countries, we identified the expansion of non-standard forms of work, transformative economic change and shifts in business organization and weakening of unions as overarching. Furthermore, labour markets were also subject to country-specific challenges.  All in all, since 1990, a remodeling of the broader landscape of employment institutions - including employment-related policies – has been going on against the background of a rapidly changing economic and business context with numerous implications for labour markets. We end the paper with some suggestions for forward-looking thinking and creativity on the part of leading policy-makers and unionists.