Transposition of the EU Directive


Belgium.
The rules of the Directive are mainly implemented by the nation-wide collective bargaining agreement n°32bis of 7 June 1985 (CBA 32bis).

France.
The rules on transfer of undertakings are mainly enshrined in articles L. 1224-1 to L. 1224-4 of the French labor code which largely preexisted the Directive. 

Germany.
The rules of the Directive are mainly implemented in Section 613a of the German Civil Code (Bürgerliches Gesetzbuch).

Italy.
The rules of the Directive are mainly implemented in Article 2112 of the Italian Civil Code and Article 47 of Law No. 428 of December 29, 1990.

UK.
The rules on transfer of undertakings are contained in the Transfer of Undertakings (Protection of Employment) Regulations 2006 (SI 2006/246), as amended (“TUPE”).

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