Quality Jobs Act

124 submissions in the snapshot (111 from organisations), portal total 124. Feedback list on the portal.

111 of 111 organisation submissions analysed; the model reads them as: opposes 11 supports 14 wants changes 68 18 held back for review (low confidence).

• DSLV Bundesverband Spedition und Logistik Business association, DEU; register: Trade and business associations model reads as: opposes source
  • Do not introduce further EU legislation on subcontracting as it is deemed neither necessary nor proportionate.

    DSLV supports the objective of preventing labour exploitation and unfair competition in subcontracting chains but considers further EU legislation neither necessary nor proportionate.

  • Avoid blanket high-risk sector labels, chain length restrictions, and chain-wide liability.

    Blanket high-risk sector labels, restrictions on chain length, chain-wide liability or additional occupational-safety obligations would impose disproportionate administrative burdens, legal uncertainty and higher costs, undermine supply-chain resilience and risk market concentrationwithout a sufficiently robust evidence base.

  • Focus on stronger cross-border cooperation and better enforcement of existing rules rather than creating new horizontal rules.

    Priority should therefore be given to stronger cross-border cooperation and better application of current law rather than new horizontal rules.

• European Youth Forum NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: supports source
  • Adopt a new settlement of workers rights fit for the 21st century.

    We need a new settlement of workers rights fit for the 21st century.

  • Ensure the Quality Jobs Act is ambitious.

    The Quality Jobs Act must be ambitious and set a precedent to say that work shouldn't make us unwell.

• AsIAm NGO, IRL model reads as: wants changes source
  • Embed disability accessibility and equality across all policy areas of the Act with the involvement of DPOs and disabled people.

    We recommend that the Quality Jobs Act: Embed disability accessibility and equality across all policy areas, with meaningful involvement of Disabled Persons Organisations (DPOs) & Disabled people in design, implementation and monitoring.

  • Strengthen reasonable accommodations in practice to address barriers during recruitment, retention, progression, and mobility.

    Strengthen reasonable accommodation in practice. EU action should address barriers to requesting and implementing accommodations, including disclosure and stigma around disability.

  • Ensure that algorithmic management and AI systems do not reproduce disability discrimination against workers.

    Ensure algorithmic management and AI do not reproduce disability discrimination. Workers should have information about systems affecting recruitment, performance management, scheduling or monitoring; and have safeguards against discriminatory processes/outcomes; and accessible complaints/oversight processes.

• AGE Platform Europe NGO, BEL model reads as: wants changes source
  • Strengthen the implementation and enforcement of equal treatment legislation and promote age-inclusive employment practices.

    The Quality Jobs Act should therefore strengthen the implementation and enforcement of equal treatment legislation and promote age-inclusive employment practices.

  • Ensure that digitalisation enhances job quality and that the green transition draws on the knowledge of older workers.

    The Quality Jobs Act should ensure that digitalisation enhances, rather than undermines, job quality, and the green transition must draw on the knowledge of older workers.

  • Promote a life-course approach to ensure sustainable working lives through adaptable working conditions, health and safety, and flexible working arrangements.

    Finally, the Quality Jobs Act should promote a life-course approach to ensure sustainable working lives in all their diversity.

• Cassandra Foundation Company, GBR model reads as: wants changes source
  • Workers should receive decision-specific explanations when automated systems influence key employment actions.

    Workers should receive an accessible explanation when an automated system materially influences task allocation, scheduling, performance assessment or disciplinary action.

  • Human reviewers must have the actual authority, time, and training to reconsider and change disputed decisions.

    A reviewer should have the authority, relevant records, training and time to reconsider a disputed decision.

  • Assess whether workplace scheduling and performance targets indirectly penalise workers during their rest time.

    Assess whether scheduling, response-time scores or performance targets indirectly penalise workers for not responding during rest time.

• AEGEE-Europe NGO, BEL model reads as: wants changes source
  • Ensure the proposed right to disconnect includes effective protection from adverse treatment and negative consequences.

    Protection from adverse treatment and negative consequences needs to work in practice, not just on paper.

  • Establish proper transparency, meaningful human involvement, and clear limits regarding algorithmic management and artificial intelligence at work.

    There should be proper transparency and information, meaningful human involvement, and clear limits on what these systems can do.

  • Strengthen occupational safety and health rules to adequately address psychosocial and ergonomic risks.

    Psychosocial and ergonomic risks are just as real as more traditional workplace risks.

• Automotive Industry Association of the Slovak Republic Other, SVK model reads as: opposes source
  • Reject additional or new regulations on telework and the right to disconnect, focusing instead on enforcing existing legal frameworks.

    Where a culture of constant availability exists, this is not a matter that should be addressed through additional or new regulations.

  • Limit the employer's responsibility for adverse health consequences when employees work outside the employer's premises.

    From this perspective, the question arises as to whether the employer should bear responsibility for adverse consequences affecting the employee even when the employee is not working on the employers premises.

  • Consider reducing permanent work from home or telework to protect employees' mental well-being.

    Therefore, if we are to discuss the protection of employees health, consideration should also be given to whether permanent work from home or telework should be reduced.

• University of Ferrara Academic or research institution, ITA model reads as: supports source
  • Introduce an EU regulation on working conditions in subcontracting chains.

    An EU regulation on working conditions in subcontracting chains is needed to ensure fair competition and protect workers rights throughout the entire chain.

• Workday Company, BEL; register: Companies & groups model reads as: opposes source
  • Advise against introducing binding rules on AI and algorithmic management at work.

    Workday takes the view that any EU action in this area should prioritise the effective implementation and consistent enforcement of the existing EU legislative framework and advises against introducing binding rules on AI and AM at work, as this would add further complexity and cost, while slowing AI adoption across the EU.

  • Focus policy efforts on the consistent implementation and effective enforcement of existing laws across Member States.

    Given the strength and breadth of the existing framework, policy efforts should focus on ensuring consistent implementation and effective enforcement across Member States rather than introducing new laws.

  • Provide practical guidance to help stakeholders navigate the existing regulatory landscape.

    The European Commission should provide practical guidance to help stakeholders and authorities navigate the existing regulatory landscape, focusing specifically on applying current labour laws within AI- and AM-enabled workplaces.

• European Federation of Salaried Doctors - FEMS NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Recognise medical work as an arduous occupation within the European approach to quality jobs.

    FEMS therefore calls for the recognition of medical work as an arduous occupation, while recognising that the degree and nature of arduousness may vary according to specialty, working environment, workload and professional exposure.

  • Develop tools to assess the cumulative physical, psychological, and organisational burden of medical work.

    FEMS particularly recommends the development and use of tools capable of assessing the cumulative physical, psychological and organisational burden of medical work over the course of a professional career.

  • Implement prevention, protection, and appropriate compensation based on the cumulative burden.

    The objective should be to identify risks at an early stage, implement preventive measures, adapt working conditions throughout the professional life and, where exposure cannot be eliminated, provide appropriate protective and compensatory measures.

• Micro company, BEL NGO, BEL model reads as: wants changes source
  • Explicitly reference and embed Supported Employment and the Supported Employment Quality Framework into the Quality Jobs Act.

    To tackle labor shortages and structural skill gaps, the legislation must explicitly reference Supported Employment and its operational tool, the Supported Employment Quality Framework.

  • Recognize external job coaches and workplace mentors in updated Occupational Safety and Health Directives.

    As Occupational Safety and Health Directives (89/654/EEC and 90/270/EEC) are updated, the Act must formally recognize external job coaches and workplace mentors as key elements for mental health protection and burnout prevention.

  • Establish mandatory human-in-the-loop protections regarding algorithmic management and AI monitoring.

    Automated monitoring and performance algorithms often unfairly penalize neurodivergent workers due to rigid metrics (e.g., typing speed, eye movement). Mandatory "human-in-the-loop" protections are necessary.

• FNOPI - Federazione Nazionale Ordini Professioni Infermieristiche Public authority, ITA model reads as: wants changes source
  • Explicitly address the specific challenges and conditions of the healthcare sector in the Quality Jobs Act.

    FNOPI (Italy's National Federation of Nursing Boards) supports the EU's Quality Jobs Act but calls for it to explicitly address the healthcare sector's specific conditions, given an ageing population, rising care complexity, and workforce shortages.

  • Prevent ergonomic risks and overload via safe staffing levels and career-long recognition of physical strain.

    Health & safety preventing ergonomic risks and overload through adequate staffing levels ("safe staffing") and recognition of cumulative career-long exposure to shift work and physical strain.

  • Introduce structural protections against work-related stress, third-party violence, and ensure a genuine right to disconnect.

    Psychosocial risks & violence structural measures against work-related stress and third-party violence, plus a genuine right to disconnect.

• ENSIE - European Network of Work Integration Social Enterprises NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Develop a Quality Jobs Act that actively supports Work Integration Social Enterprises (WISEs).

    ENSIE recommends that the European Commission develop a Quality Jobs Act that supports WISEs, as one of the main drivers of quality jobs for workers with support needs.

  • Tackle discrimination and disadvantage linked to personal characteristics through legislation and policy.

    discrimination and disadvantage linked to personal characteristics need to be tackled through legislation, policy and awareness raising to ensure equal access to quality jobs.

  • Accelerate the development of the WISE model in countries where it is still emerging.

    the Quality Jobs Act should accelerate the development of WISEs in countries where the model is still emerging.

• Lega Nazionale delle Cooperative e Mutue Business association, ITA model reads as: wants changes source
  • Align new EU measures with existing EU and national legislation to pursue regulatory simplification.

    we believe that any new measures should align with, rather than add to, the existing body of European Union legislation and the well-functioning regulatory frameworks already into force within the Member States.

  • Prioritise the application of existing rules and tools in health and safety rather than introducing new legislation.

    On health and safety at work, we believe that the priority for countries such as ours should not necessarily be additional legislation, but rather the implementation of tools, technologies and procedures ensuring the full application of existing rules and best practices.

  • Establish common transparency and safeguard standards across Member States for procurement and subcontracting.

    common standards of transparency and safeguards across Member States must be established, supported by effective monitoring, enforcement and sanctions systems, including at a cross-border level.

• Stichting Fair Trade Advocacy Office NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Embed a human-rights and environmental due diligence approach as the core logic of the Act with proportionate subcontracting liability.

    An HREDD approach as the organising logic of the Act, with EU-wide and proportionate liability in subcontracting chains;

  • Provide comprehensive protection for all workers, including subcontracted, migrant, seasonal, and home-based workers.

    Comprehensive protection for all workers, including subcontracted, migrant, seasonal and home-based workers, inside the EU and, where the EU has leverage, beyond it;

  • Operationalise the Employer Pays Principle so recruitment costs are borne entirely by employers.

    It is essential that the Quality Jobs Act operationalises the Employer Pays Principle, so that the costs of gaining employment, including recruitment fees, should fall on the employer and never on the worker, least of all on migrant workers.

• AWARE NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Incorporate workplace cardiac preparedness into the occupational health and safety standards of the Quality Jobs Act.

    The Quality Jobs Act should recognise workplace cardiac preparedness as an element of modern occupational health and safety standards.

  • Promote CPR training, ensure access to and maintenance of AEDs, and encourage cardiovascular assessments.

    This should include promoting regular first aid and CPR training, ensuring access to and maintenance of AEDs, and providing workers with practical training on how to use them, while encouraging employers to consider cardiovascular risks in workplace health and safety assessments.

  • Integrate cardiac preparedness into the Quality Jobs Act using a proportionate and risk-based approach.

    Integrating cardiac preparedness into the Quality Jobs Act would be a practical step towards making quality jobs safer jobs.

• Micro company, BEL NGO, BEL model reads as: wants changes source
  • Treat quality employment and labour-market inclusion as a single integrated policy agenda.

    CEFECs central message is that quality employment and labour-market inclusion must be treated as one integrated policy agenda.

  • Address access to, retention in, and progression within quality employment for disadvantaged groups.

    A Quality Jobs Act should address not only the quality of existing jobs, but also access to, retention in and progression within quality employment for people facing the greatest barriers to the labour market.

  • Make the social inclusion dimension more explicit and operational within the Quality Jobs Act.

    CEFEC therefore considers that the social inclusion dimension should become more explicit and operational in the Quality Jobs Act.

• European Disability Forum (EDF) NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Extend reasonable accommodation provisions under Directive 2000/78/EC and clarify employer responsibilities.

    Greatly extend on the provisions on reasonable accommodation in Directive 2000/78/EC, in line with General Comment 8 to the UN Convention on the Rights of Persons with Disabilities, with clarification on employers responsibilities and the role of state aid.

  • Set minimum standards for undertakings employing high proportions of disabled workers to ensure fair wages and training.

    Set minimum standards for undertakings employing a higher proportion of workers with disabilities, moving away from models that do not respect workers right, and ensuring that employers offer fair salaries, facilitate training and offer pathways to the open labour market.

  • Promote flexibility to combine disability allowances and social protection with employment income.

    Promote flexibility to combine social protection (including disability allowance) with income earned through employment to avoid in-work poverty.

• European Women's Lobby NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Mainstream gender equality extensively across all sections of the initiative using an intersectional approach.

    Therefore, EWL argues that, in line with the Roadmap for Womens Rights and the Gender Equality Strategy 2026-2030, the upcoming Quality Jobs Act must mainstream gender equality more extensively across all sections and ensure an intersectional approach.

  • Adopt binding legislation on gender-based violence and harassment at work with a definition aligned to ILO Convention 190.

    EWL supports the call of ETUC and other workers organisations for binding legislation on gender-based violence and harassment at work, as opposed to a focus on soft law instruments such as guidelines.

  • Provide an extended period of paid maternity leave across Europe.

    The Quality Jobs Act should foresee an extended period of paid maternity leave in Europe which would also provide equal rights for (pregnant) women in the context of free mobility of workers.

• European Alliance of Associations for Rheumatology NGO, CHE; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Recognise the prevention and management of rheumatic and musculoskeletal diseases as a strategic priority in the Quality Jobs Act.

    Recognise that the prevention and management of RMDs is a strategic challenge that must be addressed to achieve the European Commissions targets on employment, poverty reduction and social convergence, and a priority within the Quality Jobs Act.

  • Establish an enforceable right to disconnect with minimum protections and support for collective bargaining.

    Establish a right to disconnect with enforceable minimum protections, including measures to enable workers to disconnect during rest time and protect them from adverse treatment or negative consequences for exercising this right, and support collective bargaining and additional measures to address the always-on culture and associated psychosocial risks.

  • Update the Workplace Directive to include explicit requirements on workplace ergonomics and ergonomic risk assessments.

    Introducing an explicit section on workplace ergonomics, requiring dimensions of furniture and equipment to be adapted to workers anatomical and physiological characteristics and to the nature of the tasks performed.

• CLECAT - European association for forwarding, transport, logistic and Customs services Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Prioritise the enforcement of existing EU and national rules supported by cross-border cooperation and the European Labour Authority.

    give priority to enforcement of the existing EU and national acquis, supported by stronger cross-border cooperation and a reinforced operational role for the European Labour Authority (ELA);

  • Complete a robust sector-specific evidence assessment distinguishing transport-service subcontracting from labour intermediation before proposing legislation.

    complete a robust, current, and sector-specific evidence assessment before proposing new legislation, including a clear distinction between transport-service subcontracting and labour intermediation;

  • Reject EU-wide limits on subcontracting tiers, bans on subcontracting core activities, and full-chain joint and several liability.

    reject EU-wide limits on the number of subcontracting tiers, bans on subcontracting core activities, and full-chain joint and several liability;

• Grupo SSI Company, ESP model reads as: wants changes source
  • Explicitly recognise private homes as locations where care services are delivered.

    explicitly recognize private homes as locations where care services are delivered;

  • Ensure contracting parties are responsible for OSH compliance, backed by public support and resources.

    ensure that contracting parties are responsible for compliance with occupational health and safety requirements, supported by appropriate mechanisms, guidance and resources from public authorities;

  • Ensure sector-specific risk assessment methodologies for home-based care.

    ensure sector-specific risk assessment methodologies for home-based care;

• The European Confederation of Agricultural, Rural and Forestry Contractors (CEETTAR) Business association, SWE; register: Trade unions and professional associations model reads as: opposes source
  • Retain the existing workplace exemption for outdoor agricultural and forestry land.

    Retain the exemption: keep Article 1(2)(e) in any revised or merged Workplace Directive.

  • Address outdoor risks through the Framework Directive rather than rules designed for buildings.

    Use the existing framework: address outdoor risks under the Framework Directive, supported where needed by non-binding sectoral guidance.

  • Explicitly evaluate the impact and costs on agricultural and forestry SMEs in the impact assessment.

    Assess the impact: cover agricultural and forestry SMEs explicitly in the impact assessment, including the cost of facilities at dispersed and temporary worksites.

• Technology Industries of Finland (TIF) Company, FIN model reads as: opposes source
  • Avoid creating new employee participation rights or expanding collective rights regarding AI and algorithmic management.

    Correspondingly, there is no need to create new participation rights for worker representatives or to broaden existing collective rights, since the current legal framework already addresses these situations.

  • Refrain from introducing dedicated EU legislation on telework.

    Technology Industries of Finland (TIF) sees no need for separate EU legislation on telework, as frameworks are already established at national level through legislation, collective agreements and company policies.

  • Reject new restrictions on subcontracting chains or additional legislation in this area.

    TIF does not support new restrictions on subcontracting chains or additional EU or national legislation.

• European Veterinary Nursing Working Group Other, IRL; register: Companies & groups model reads as: supports source
• Business Software Alliance (BSA) Business association, USA; register: Trade and business associations model reads as: opposes source
  • The European Commission should avoid introducing new binding sectoral legislation on AI and algorithmic management at work and instead rely on guidance.

    BSA strongly recommends that the European Commission avoid introducing new sectoral binding measures on AI and AM at work.

  • The Commission should prioritise guidance and coordinated enforcement under existing legislative frameworks such as the AI Act and GDPR.

    Rather than seeking legislation, BSA believes that the European Commission should develop and promote guidance to help the relevant stakeholders understand, implement, comply and enforce the existing framework aforementioned.

  • Any future legislative action should only be pursued if evidence shows a specific regulatory gap.

    Any future legislative intervention should be considered only where experience demonstrates a specific and material regulatory gap

• RREUSE - Reusing and Recycling European Union Social Enterprises NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Ensure skill-building programmes better reach underrepresented groups experiencing access barriers.

    Ensuring skill building initiatives (e.g. Union of Skills) better target underrepresented groups as they face geographic, financial, or caregiving barriers to formal education access.

  • Incorporate robust social conditionalities across EU policy areas to recognize work integration social enterprises.

    Helping promote robust social conditionalities that recognise work integration social enterprises across policies such as public procurement, state aid, skills, and the circular economy (e.g. Public Procurement Act, General Block Exemption Regulation, and Circular Economy Act).

  • Support the transition of workers from social economy employment into the wider labour market.

    Facilitate workers transition from social economy employment into the broader labour market.

• IndustriAll Europe Trade union, BEL model reads as: supports source
  • Establish a legally backed Quality Jobs Act equipped with robust monitoring mechanisms.

    A legally backed Quality Jobs Act with strong monitoring mechanisms and legal instruments.

  • Impose mandatory social conditionalities on all public funding.

    Mandatory social conditionality on all public fundingno public money without good jobs.

  • Strengthen labour inspections, expand trade union rights, and prohibit exploitative subcontracting.

    Stronger labour inspections, more rights for trade unions, and a ban on exploitative subcontracting.

• Micro company, PRT Other, PRT model reads as: wants changes source
  • Ensure the Quality Jobs Act mainstreams disability rights in compliance with the CRPD.

    The National Monitoring Mechanism for the Implementation of the Convention on the Rights of Persons with Disabilities (Me-CRPD) considers it crucial that the future Quality Jobs Act mainstreams the rights of persons with disabilities and is developed and implemented in accordance with the Convention on the Rights of Persons with Disabilities (CRPD), to which the European Union is a party.

    machine translation by the Commission, original in PT
  • Guarantee accessibility and reasonable accommodation across the full career path while fostering inclusive employment.

    In this context, the Me-CRPD recommends that the future European framework should ensure the accessibility and effective provision of reasonable accommodation throughout the entire career path; recognise the diversity of persons with disabilities and the multiple and intersectional forms of discrimination; promote the transition from segregated employment to an open, inclusive and accessible labour market; and strengthen the permanence and return to work of people who acquire or experience a disability during their working life.

    machine translation by the Commission, original in PT
• ONCE Foundation Other, ESP model reads as: supports source
  • Translate EU social and disability rights frameworks into concrete measures that improve access to and quality of employment for persons with disabilities.

    In this context, the ONCE Foundation considers the Quality Jobs Act an opportunity to translate the principles of the European Pillar of Social Rights, the Disability Employment Package, the European Disability Strategy 2021-2030 and the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD) into concrete measures that improve both access to employment and the quality of employment for persons with disabilities.

  • Guarantee fair working conditions, equal opportunities, safe workplaces, skills development, and inclusion for all workers.

    Ensuring that all workers benefit from quality employment is essential to support competitiveness, cohesion of our society and sustainable economic growth, by guaranteeing fair working conditions, equal opportunities, safe and healthy workplaces for all, skills development and career progression, and genuine inclusion in working life.

• UNI Europa Trade union, BEL model reads as: supports source
  • Establish a European framework that strengthens collective bargaining and guarantees the full application of collective agreements.

    A European legal and political framework that strengthens collective bargaining and ensures the full application of collective agreements. EU action must support trade unions ability to bargain collectively at national level, especially through sectoral and multi-employer bargaining.

  • Adopt EU legislation on AI and algorithmic management that enables collective bargaining and respects the human-in-command principle.

    EU legislation on AI and algorithmic management in the workplace that enables collective bargaining. Trade unions and worker representatives must be involved at an early stage in assessing needs and in the deployment, implementation and follow-up of AI systems.

  • Introduce a legislative response to protect workers mental health and prevent psychosocial risks.

    A legislative response to protect workers mental health and prevent psychosocial risks. This requires stronger prevention and a stronger role for trade unions, collective bargaining and social dialogue in occupational health and safety.

• AsIAm Ireland's Autism Charity Other, IRL model reads as: supports source
  • Recognise disability inclusion and accessibility as integral components of quality employment.

    Recognises disability inclusion and accessibility as integral components of quality employment.

  • Promote the effective implementation of reasonable accommodation and inclusive workplace practices for disabled and Autistic workers.

    Promotes the effective implementation of reasonable accommodation and inclusive workplace practices for disabled and Autistic workers.

  • Consider the specific barriers faced by Autistic people across changing workplace environments, digitalisation, recruitment, and health and safety.

    Considers the specific barriers experienced by Autistic people when developing policies on the future of work, including changing workplace environments, digitalisation, recruitment practices and workplace health and safety.

• Micro company, LTU NGO, LTU model reads as: supports source
  • The European Commission should develop a Quality Jobs Act that supports Work Integration Social Enterprises (WISEs).

    LISVA recommends that the European Commission develop a Quality Jobs Act that supports WISEs, as one of the main drivers of quality jobs for workers with support needs.

  • The initiative should recognize the social economy as an essential driver of inclusive labour markets.

    recognising the social economy, including Work Integration Social Enterprises, as a vital driver of inclusive labour markets;

  • The Commission should establish quality job standards tailored to workers with support needs.

    setting quality job standards for workers with support needs;

• European Union of the Deaf NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • The Quality Jobs Act must promote data disaggregated by disability group and set employment targets.

    promote data disaggregated by disability group, including deaf people, and employment targets;

  • Publicly funded professional sign language interpretation must be guaranteed across all stages of employment as reasonable accommodation.

    reinforce reasonable accommodation, clarifying that publicly funded professional sign language interpretation applies at every stage of employment and cannot be replaced by captioning or automated tools against the worker's expressed needs, and recognising sign language-inclusive work environments as a component of quality jobs;

  • The Act should introduce safeguards on algorithmic management aligned with the AI Act.

    introduce safeguards on algorithmic management, aligned with the AI Act, that apply to all workers;

• City of Stockholm Public authority, SWE model reads as: opposes source
  • The EU should refrain from introducing further legislation in the field of labour law.

    The city does not therefore see a need for more EU legislation in the field of labour law, but wishes to stress the importance of the work of the social partners and of maintaining national labour market models.

    machine translation by the Commission, original in SV
  • The Commission should provide clarity and guidance on the existing EU legal framework rather than new legislative requirements.

    Instead of further legislation, the City sees that clarity and guidance on the current EU legal framework could contribute to national work.

    machine translation by the Commission, original in SV
  • Employers should be afforded the space to remain active in complementary areas such as tackling welfare crime.

    It is essential that employers are given the space and opportunity to be active also in areas that complement labour law such as combating welfare crime.

    machine translation by the Commission, original in SV
• European Transport Workers' Federation Trade union, BEL; register: Trade unions and professional associations model reads as: wants changes source
  • The initiative should mandate joint and several liability throughout the subcontracting chain.

    Mandating joint and several liability across the subcontracting chain (full chain liability).

  • The legislation should cap subcontracting chains at a maximum of two levels.

    Limiting the subcontracting chain to a maximum of 2 levels.

  • The directive should ensure equal treatment for subcontracted workers compared to directly employed workers.

    Guaranteeing equal treatment of workers across the chain, so that workers hired by subcontractors work on the same terms as workers directly employed by the lead contractor.

• European Institute for Gender Equality - EIGE Other, LTU model reads as: supports source
  • The Commission should integrate gender equality principles and ensure workplaces are free from gender-based violence.

    The input includes research covering the following areas: building inclusive and quality labour markets; gender-based violence-free workplaces as a foundation for quality jobs; platform work, social protection and gender equality; and gender Equality as a quality jobs principle.

  • The initiative should tackle gender stereotypes and bias in the design and deployment of AI.

    Finally, EIGE provides recommendations that strengthen job quality and equal career opportunities; address inherent gender stereotypes, bias and discrimination in AI design and use; protect and empower platform workers; and suggest how to promote safety, respect and accountability in all workplaces.

• COFACE Families Europe NGO, BEL model reads as: wants changes source
  • Recognise work-life balance and care responsibilities as integral parts of job quality.

    -recognises work-life balance and the ability to combine employment with care responsibilities as integral dimensions of job quality;

  • Legislate on the right to disconnect.

    -legislates on the right to disconnect;

  • Promote accessible and non-discriminatory flexible working arrangements.

    -promotes accessible and non-discriminatory flexible working arrangements for workers, particularly parents and carers;

• CECOP Business association, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Incorporate a human-in-control principle for algorithmic management based on cooperatives.

    1. Ensure a human-in-control principle based on cooperatives approach to algorithmic management

  • Integrate the worker-ownership model throughout the initiative.

    2. Mainstream the worker-ownership model throughout the Quality Jobs Act

  • Provide targeted support for cooperative training programmes to ensure a fair transition.

    3. Provide targeted support to cooperatives to expand their training programmes to ensure a fair job transition for all

• Association Européenne des Conservatoires NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Ensure fair remuneration covers all aspects of professional artistic work.

    AEC therefore calls for fair remuneration to cover the full scope of professional activity, including preparation, rehearsal, research and creation.

  • Adapt social protection schemes to intermittent, freelance, and mobile careers.

    Social protection systems must also reflect the realities of intermittent, project-based, freelance and highly mobile careers.

  • Utilise public funding as a driver to improve working conditions.

    AEC further supports the direction of the sector Blueprint for the EU Artists Charter in making public funding a driver of better working conditions.

• Social Economy Europe (SEE) Other, ESP; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Formally recognise the social economy as an essential contributor to quality employment.

    1. Recognise the social economy as a key driver of quality jobs.

  • Incorporate structured participation of social economy organisations into EU employment governance.

    2. Embed structured social economy participation in EU employment governance.

  • Align the initiative coherently with broader EU social and economic policies.

    3. Ensure coherence with wider EU policy initiatives.

• Inclusion Europe NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Exclude sheltered workshops lacking labour rights and fair wages from being classified as quality jobs.

    state that sheltered workshops which do not guarantee labour rights and decent wage cannot be qualified as quality jobs.

  • Facilitate the move from sheltered workshops to open employment and secure quality standards.

    support the transition from sheltered workshops to the open labour market, and guaranteeing quality working condition in sheltered workshops.

  • Mandate that algorithmic management information and review be provided in accessible and understandable formats.

    Transparency and human review should require a form the worker understands, easy-to-read on request.

• Confederation of German Employers’ Associations Business association, DEU; register: Trade and business associations model reads as: opposes source
  • Avoid creating additional regulations on artificial intelligence and algorithmic management.

    There is no need for additional regulation for artificial intelligence (AI) and algorithmic management.

    machine translation by the Commission, original in DE
  • Refrain from introducing new legislative obligations regarding subcontracting.

    The Commission must refrain from introducing new rules on subcontracting.

    machine translation by the Commission, original in DE
  • Ensure agreements between social partners take precedence over new EU regulatory measures.

    Social partner agreements must always take precedence over new EU regulation.

    machine translation by the Commission, original in DE
• Autism-Europe NGO, BEL model reads as: wants changes source
  • Extend reasonable accommodation beyond Directive 2000/78/EC and clarify employer responsibilities, public procurement, and state aid.

    Greatly extend reasonable accommodation beyond Directive 2000/78/EC, as per UNCRPD General Comment 8, clarifying employer responsibilities, Public Procurement practices and state aid;

  • Permit the combination of disability allowances with earned income to prevent in-work poverty.

    Allow disability allowance to be combined with earned income to prevent in-work poverty;

  • Ensure algorithmic management and artificial intelligence do not reproduce discrimination through transparency and human oversight.

    Ensure algorithmic management and artificial intelligence don't reproduce employment discrimination, through transparency, human involvement and accessible ove

• Culture Action Europe NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Provide stronger rights, consultation, consent, fair remuneration, and the option to opt out when AI is used in cultural work.

    On AI, stronger rights for artists and cultural workers when automated systems are used to select, rank or assess them, the right to know when AI is involved and to request human review. We also call for consultation before AI is introduced in ways that affect work, pay or professional opportunities, and for clear consent and fair remuneration where artists voices, images or performances are used or reproduced by AI. We also advocate for the right not to use AI.

  • Apply occupational health and safety protections across all working locations and employment statuses.

    On health and safety, protection should apply regardless of employment status and follow the worker wherever the work takes place, including on tour, at festivals, film locations and other temporary sites.

  • Enforce social standards, declared work, and full compliance with labour obligations across subcontracting and public funding chains.

    On subcontracting and public funding, social standards should apply throughout the chain. EU and national funding and public contracts should require declared work, correct classification, applicable pay and compliance with labour and social security obligations, including by subcontractors and project partners.

• Micro company, GBR Other, GBR model reads as: wants changes source
  • Prioritise situations where low wage floors, weak collective bargaining, insecure work, and fragmented subcontracting overlap.

    First, within the QJAs scope, measures to address living-wage gaps should prioritise situations where low wage floors, weak collective bargaining, insecure work and fragmented subcontracting overlap, with particular attention to garment and textile workers and to migrant, seasonal, agency, subcontracted and homeworkers.

  • Strengthen enforcement through well-resourced risk-based inspections, multilingual complaints channels, and chain-wide remedy mechanisms.

    Second, enforcement should be strengthened through adequately resourced, risk-based and, where appropriate, unannounced inspections; checks of payroll, working-time records, deductions, recruitment fees and accommodation charges; confidential engagement with workers and trade unions; multilingual complaints channels and non-retaliation safeguards; recovery of wage arrears; dissuasive sanctions; and mechanisms enabling workers to obtain remedy elsewhere in the subcontracting chain.

  • Explicitly align the Quality Jobs Act with the living-wage provisions of the CSDDD and CSRD.

    Finally, the QJA should explicitly align with the living-wage provisions of the CSDDD and CSRD, including through its recitals, implementation guidance and transparency requirements.

• Micro company, BEL NGO, BEL model reads as: wants changes source
  • Improve working conditions and enforce workers' rights taking into account people with Down syndrome.

    1.Working conditions for people with Down syndrome must be improved so they can already as a start be part of the labour market. 2.Enforcement of workers' rights must be understood taking into consideration people with Down syndrome too, in order to achieve a fair, equal and inclusive labour market.

  • Protect the right to disconnect specifically for relatives providing care to family members with disabilities.

    3. The right to disconnect should apply, specially, to parents and siblings taking care of their relative with a disability avoiding any type of discrimination.

  • Implement supported employment and reasonable accommodation under just transition initiatives.

    4. Just transition should also be extended with special regard to people with Down syndrome. Reasonable accommodation, such as supported employment methodology should be implemented in order to guarantee the full inclusion in the labour market.

• European Platform for Rehabilitation NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Regulate algorithmic management and AI recruitment to prevent discrimination against persons with disabilities.

    2. Algorithmic Management and AI at work: EPR would support the creation of EU legislation, such as a Directive, regulating the use of algorithms for managing, monitoring and recruiting workers that would address the risks of discrimination that candidates and employees often face with AI algorithms, including the risks experienced by persons with disabilities.

  • Prevent cost pressures in subcontracting and commissioning chains from undermining working conditions or disability service quality.

    4. Protection of Workers rights in subcontracting chains: The Quality Jobs Act should therefore ensure that cost pressures throughout subcontracting and commissioning chains do not undermine decent working conditions or the quality and continuity of services for persons with disabilities.

  • Ensure effective enforcement with accessible redress mechanisms, rights protection, and involvement of disability organisations.

    6. Enforcement and the role of social partners: The Quality Jobs Act should focus on effective enforcement, including: accessible complaint and redress mechanisms; effective enforcement of rights relating to non-discrimination and reasonable accommodation; and involving persons with disabilities and their organisations in the development and implementation of policies affecting their employment.

• European Roma Grassroots Organisations (ERGO) Network NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Explicitly address racial and intersectional discrimination and mainstream equality across the initiative.

    ERGO Network welcomes the Quality Jobs Act, but the initiative must explicitly address racial and intersectional discrimination, including antigypsyism.

  • Introduce chain liability, risk-based inspections, and sanctions in subcontracting chains and labour intermediaries.

    The Act should introduce chain liability, risk-based inspections, and strong sanctions for abusive employers and intermediaries.

  • Establish safeguards against algorithmic bias in recruitment, task allocation, performance evaluation, and dismissals.

    Algorithmic management and AI require safeguards against discriminatory recruitment, work allocation, performance assessment, and dismissal.

• EFFE Other, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Explicitly cover personal and household services and ensure alignment with the European Care Deal and Strategy.

    The Act should explicitly cover the sector and be designed in continuity with the Care Deal and the European Care Strategy, so that PHSworkers, household employers benefit from coherent measures, including on the attractiveness of care jobs and work-life balance.

  • Recognise the specific non-corporate status of household employers and consult their representative organisations.

    The Act should recognise their specific status and consult their representatives.

  • Adapt health and safety frameworks to the home care context with balanced obligations, guidance, and social dialogue.

    We call for: recognition of the specificity of the sector, with balanced rights and obligations for household employers, backed by public guidance, tools and resources; structured social dialogue in the branch of domestic work and home care sector, through collective agreements and dedicated joint governance bodies, to develop adapted prevention mechanisms, including on musculoskeletal and psychosocial risks; a two-way approach to violence and harassment: care workers can be exposed to it in isolation, but household employers, as care recipients, can also be victims; EU-level research on occupational health in home care.

• Micro company, BEL NGO, BEL model reads as: supports source
  • The Quality Jobs Act should define accessible communication and timely reasonable accommodation as core components of quality employment.

    EFHOH calls on the Commission to ensure that the Quality Jobs Act recognises accessible communication and timely reasonable accommodation as core elements of quality employment.

  • The Act should address inclusive recruitment, assistive technology, telework accessibility, and enforcement of reasonable accommodation duties.

    The Act should also address inclusive recruitment, accessible telework and hybrid work, available assistive technology, flexible work arrangements, access to essential workplace information especially in case of emergencies, listening fatigue and psychosocial risks, and stronger enforcement of employer duties on reasonable accommodation.

• European Tech Alliance Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • The Commission should identify genuine gaps in existing EU legislation before introducing new horizontal rules.

    If the Quality Jobs Act is to support both workers and competitiveness, it should consolidate and clarify what exists rather than add to it.

  • Consultation duties regarding algorithmic systems should be limited to decisions causing material and lasting impacts.

    Scope of consultation: consultation duties should be triggered by decisions that materially and lastingly change working conditions or earnings, not by routine software updates or security patches.

  • Liability in subcontracting chains should be proportionate and limited to parties with actual control and capacity to remedy breaches.

    Liability belongs with the party that is genuinely able to prevent or remedy a breach, and extending liability beyond that point would be disproportionate and would weigh most heavily on fast growing European companies.

• European Association of Service Providers for Persons with Disabilities (EASPD) NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • People with disabilities, social services staff, and informal carers should be explicitly prioritized in the initiative.

    People with disabilities, the social services workforce, and informal carers to be explicitly and visibly named as priorities of the Act, to ensure that targeted, effective measures address them.

  • The social economy must be placed at the center of the legislative act.

    Social economy (work integration social enterprises, sheltered employment providers, not-for-profit social service providers) must be placed at the centre of the Act, both because of the economic weight it carries in its own right and because it is, in practice, the main vehicle currently delivering employment to people with disabilities and other under-represented groups.

• Sonae SGPS, S.A. Company, PRT; register: Companies & groups model reads as: wants changes source
  • The initiative should evaluate and enforce existing rules before creating new obligations, avoiding regulatory overlap.

    The Quality Jobs Act should first assess whether identified challenges can be addressed through effective implementation, clarification and enforcement of the existing framework before creating additional obligations.

  • Information and consultation procedures across instruments should follow a single coherent procedure and the once-only principle.

    Where several instruments impose information or consultation duties, employers should be able to comply through a single coherent procedure rather than parallel processes.

  • Liability in contracting chains must remain proportionate to each undertaking's own control rather than imposing automatic joint and several liability.

    A general system of automatic joint and several liability throughout subcontracting chains could create legal uncertainty and transfer public enforcement responsibilities to compliant companies without necessarily improving worker protection.

• DigitalTrade4.EU Other, EST; register: Other organisations, public or mixed entities model reads as: wants changes source
  • Ensure that future EU rules on algorithmic management complement rather than duplicate the AI Act.

    The contribution argues that future EU rules on algorithmic management should complement, rather than duplicate, the AI Act.

  • Apply enhanced safeguards where an automated process has an observable role in decisions with significant consequences for workers.

    Enhanced safeguards should apply where an automated process has an observable role in decisions with significant consequences for workers, while routine administrative processing should remain outside this targeted layer.

  • Adopt a two-level approach combining collective governance and proportionate decision-level accountability.

    The contribution also proposes a two-level approach: collective governance of relevant workplace systems, including meaningful information and consultation with worker representatives, combined with proportionate decision-level accountability for significant individual outcomes.

• Clase Finanzas Sostenibles UCM Academic or research institution, ESP model reads as: wants changes source
  • Increase transparency about how algorithmic management systems operate.

    The EU should ensure the responsible use of algorithmic management by increasing transparency about how these systems operate

  • Ensure human oversight of decisions and set limits on surveillance and data collection.

    ensuring human oversight of decisions, setting limits on surveillance and data collection

  • Implement controls to prevent biases and promote greater participation of workers and their representatives.

    implementing controls to prevent potential biases, and promoting greater participation of workers and their representatives.

• CONFAPI - Confederazione italiana della piccola e media industria privata Business association, ITA; register: Trade and business associations model reads as: supports source
  • Prioritize simplification, better enforcement, and legal clarity.

    CONFAPI welcomes this second phase representing a crucial opportunity to prioritize simplification, better enforcement, and legal clarity.

  • Focus on administrative simplification within the consultation framework.

    In this context, CONFAPI strongly welcomes the inclusion of a dedicated focus on administrative simplification within the current consultation framework.

• F.A.I. Federazione Autotrasportatori Italiani Business association, ITA; register: Trade and business associations model reads as: wants changes source
  • Apply principles of proportionality, balance and legislative economy to ensure the consistent application of the existing regulatory framework.

    F.A.I. considers it appropriate to stress the need for an approach based on the principles of proportionality, balance and legislative economy, aimed at ensuring the consistent, harmonious and effective application of the existing regulatory framework.

    machine translation by the Commission, original in IT
  • Enhance the role of dialogue between social partners to define effective solutions that respect national specificities and sector needs.

    F.A.I. also stresses the importance of enhancing the role of dialogue between the social partners, recognising their essential contribution in defining and implementing effective and sustainable solutions to protect workers, also in the light of national specificities and the needs of the various economic and production sectors.

    machine translation by the Commission, original in IT
• Swedish Association of Local Authorities and Regions (SALAR) Other, SWE model reads as: wants changes source
  • Recognise the role of social partners and national, sectoral and local realities.

    As job quality is multidimensional and context-dependent, its promotion must recognise national, sectoral and local realities and the central role of social dialogue and collective bargaining in determining working conditions.

  • Prioritise support for awareness-raising and guidance on existing legislation instead of proposing new overlapping rules.

    The EU should prioritise support for social partners and Member States through awareness-raising, information and guidance on existing EU legislation to improve understanding and compliance. It should do so before proposing legislation that may duplicate or overlap with existing rules and increase administrative and economic burdens on employers and enterprises.

  • Ensure any future initiative follows principles of subsidiarity, proportionality, and simplification.

    Any future initiative should follow the principles of subsidiarity, proportionality and simplification, demonstrate clear EU added value, and respect national competences, established industrial relations systems and the autonomy of social partners.

• SOLIDAR NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Include a Quality Jobs Golden Rule and Just Transition Directive provisions in the Quality Jobs Act.

    SOLIDAR calls for the Quality Jobs Act to include measures such as a Quality Jobs Golden Rule and the provisions outlined in the European Parliaments January 2026 report on a Just Transition Directive, as well as several other actions to strengthen social fairness within the clean transition.

  • Incorporate standards and inclusive employment models from the joint statement into the initiative.

    This statement sets out a shared vision that calls for more integrated and inclusive forms of employment and proposes standards for creating quality jobs for everyone.

33 more analysed submissions on the consultation page.