Letter

transposition by Estonia of Directive (EU) 2019/1152 - Ares(2025)11355769  (Please use this link only if you are an Ares user – Svp, utilisez ce lien exclusivement si vous êtes un(e) utilisateur d’Ares)

Dear Mrs Treier, dear Mrs Uusberg,

I’m contacting you about the Estonian transposition of Directive (EU) 2019/1152 on Transparent and Predictable Working Conditions (the Directive).

We have now finalised the conformity check of the notified national measures, and as announced by the Director-General of DG EMPL in the last meeting of Directors General for Industrial Relations of 13 November 2025, the Commission intends to proceed with launching infringement proceedings in cases where Member States have failed to correctly transpose the Directive.

In the case of Estonia, we have identified conformity issues with regards to the following provisions:

• Article 5(1) of the Directive: This provision of the Directive creates an obligation for the employer to provide individually to the worker, in the form or one or more documents, essential information on the employment relationship (that included in in points (a) to (e), (g), (k), (l) and (m) of Article 4(2))) at the latest on the seventh calendar day after the commencement of the employment relationship. According to the information you have notified, the Estonian measure transposing this requirement (Article 5(3) of the Employment Contracts Act - töölepingu seadus) does not create an obligation for the employer to provide the information at the latest on the seventh day, as required by the Directive, but only a right of the worker to request information and to receive it within two weeks after the request.

• Article 7(2)(a), (b) and (c): according to the information you have notified, this provision of the Directive requiring additional information to be provided for posted workers covered by Directive 96/71/EC has not been transposed.

Should you have any questions or comments at this stage, please don’t hesitate to get in touch.

Kind regards,

Adam Pokorny
Head of Unit EMPL.C.1 – Labour Law


European Commission
DG Employment, Social Affairs and Inclusion
Directorate C: Working conditions and Social dialogue