Subject: FW: transposition by Estonia of Directive (EU) 2019/1152 - Ares(2025)11355769
From: "info - MKM" <[email-masked]>
To: "info - MKM" <[email-masked]>
Date: Fri, 19 Dec 2025 12:06:13 +0200

From: POKORNY Adam (EMPL) <[email-masked] 
<mailto:[email-masked]> >
Sent: Thursday, December 18, 2025 3:19 PM
To: Thea Treier <[email-masked] <mailto:[email-masked]> >; Triin 
Uusberg <[email-masked] <mailto:[email-masked]> >
Cc: POKORNY Adam (EMPL) <[email-masked] 
<mailto:[email-masked]> >; ve_empl.c.1 (EMPL) 
<[email-masked] <mailto:[email-masked]> >
Subject: transposition by Estonia of Directive (EU) 2019/1152 - 
Ares(2025)11355769

 <https://webgate.ec.testa.eu/Ares/documentInfo/documentInfoDetailsExt.do?documentId=080166e526cb237d> 
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