Comparatively open: statutory information disclosure for consultation and bargaining in Germany, France and the UK

Information provision is an important part of all mechanisms which give employees voice at work. This paper considers the law on information disclosure for joint consultation and collective bargaining in three countries, Germany, France, and the UK, chosen for their distinctive legal and institutional arrangements, within a common European Union context. It is argued that there is coherence between the law and institutions in Germany; in France, despite extensive legal support for information provision, the law and institutions complement one another less; in the UK, there are contradictory approaches and new dilemmas confronting the traditional system. Although European Directives harmonise statutory minima, there are few signs of common disclosure practice emerging across the three countries.