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The European Connection - The battle against undeclared work

Jun 16, 2014
Spanning 15-20 years, starting back in the 80s, my team at the then External Affairs Committee of the British Association of Removers and I spent many hours addressing matters of concern to professional removal companies.



One of many such projects centred on the unfair competition element resulting from less scrupulous operators using ‘cash-in-hand’ labour or other methods of undeclared and illegal work, often termed as the ‘Black Economy’. We achieved a number of positive advances including, for example, the establishment of a dedicated ‘hot line’ to HMRC enabling members to report illegal activities anonymously.

The problems surrounding ‘undeclared work’  are not , of course, limited to the UK and during my subsequent years at FEDEMAC we created various ‘toolkits’ to assist and promote activity at national levels throughout Europe and lobbied the political institutions at a central European level.

Whilst an overnight remedy is too much to hope for, given the complexity of the issue, it is encouraging to note that the European Commission (EC) has now put forward a proposal for a Decision on establishing a ‘European Platform to enhance cooperation in the prevention and deterrence of undeclared work’. The main responsibility for tackling undeclared work still lies with the Member States (MSs) but the EC maintains that EU level action will help MSs to tackle the issues more effectively and efficiently. Cooperation between national enforcement authorities already takes place at EU level, where the work of several committees is linked to undeclared work. However, they do it on an occasional and limited basis and lessons learnt show that not all MSs take part in these exercises. There is no obligation for MSs to participate in such voluntary multilateral cooperation, nor is there a mechanism to make participation mandatory. As a result, EU level cooperation remains patchy both in terms of the MSs involved and the issues covered.

The ‘Platform’ will aim at bringing together the different enforcement authorities of all MSs. Other stakeholders, in particular the Social Partners at EU level, relevant Union decentralised agencies, such as Eurofound (a tripartite EU Agency providing knowledge to assist in the development of social and work-related policies), the European Agency for Safety and Health at Work (EU-OSHA) and international organisations, such as the International Labour Organisation (ILO) and representatives of EEA states, will have an observer status.

A number of tasks will be defined and implemented on the basis of agreed work programmes. Exchange of good practice would be the first practical step of cooperation helping to develop a better understanding about how undeclared work is tackled and who the main actors are in each MS. A ‘Knowledge Bank’ could be established to elaborate further on enforcement issues, leading to the development of common guidelines and principles and more sophisticated  forms of cooperation as mutual trust and experience build up.

Ultimately, the ‘Platform’ should also be able to undertake joint trainings and exchange of staff and coordinate operational actions, including joint inspections and data sharing.

Tony Richman


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