This master's thesis examines the implementation of European legislation on posted workers in selected EU Member States: Germany, France, Austria, and Finland. The central research problem lies in the differences between EU law and national regulations, with a focus on their implications for businesses and the rights of posted workers. The main objective was to determine how individual countries have transposed Directive 96/71/EC and its amendment Directive (EU) 2018/957 into their national legal systems, and how effectively these provisions are applied in practice. A comparative analysis was conducted on the relevant legislation, collective agreements, and enforcement mechanisms, using case studies of the four countries. The findings show that despite a common European framework, both substantive and administrative differences persist. These are reflected in the scope of inspections, levels of penalties, the obligation to appoint local representatives, and access to information. While Austria and Germany apply a more centralized and formalized approach, Finland relies on social dialogue, and France emphasizes enhanced inspection and the role of trade unions. The thesis concludes that differences in implementation affect the competitiveness of businesses and the legal certainty of workers. Although the EU legal framework defines minimum standards, their actual enforcement largely depends on the administrative capacity and political will of each Member State.
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