Share on LinkedInShare on LinkedIn

ARTICLE · 13 MAY 2026

Governing Law In Cross-border Employment

The CJEU's recent judgment in Locatrans Sàrl v ES [2025] clarifies how courts must determine which country's mandatory employment laws apply when employees work across multiple jurisdictions.

GlobalEmployment and HR
Rachel Barry
Rachel Barry
Iñigo Sebastian Garay
Iñigo Sebastian Garay
Fergal McGuinness
Fergal McGuinness
Author LinkedIn connections

The importance of mandatory rules in cross-border employment relationships. In this article we provide a practical analysis of the CJEU’s Judgment in Locatrans Sàrl v ES [2025] and its implications in an ever-more interconnected world.

A pivotal matter in today’s world of work.

Global mobility is a defining characteristic of the modern workplace. Employees are now routinely engaged in cross‑border arrangements or working from multiple jurisdictions while performing their roles. In an increasingly interconnected business environment fuelled by rapid technological developments, employers can structure their operations to avail of multijurisdictional synergies and collaboration across vast geographic distances, time zones and, significantly, legal jurisdictions, with ease.

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

See more popular content from