* : Migrant workers deserve protection, not precarity: ETUC and ETUFs reject the EC Talent Pool proposal

Brussels, 14 November 2025

Dear Co-legislators,

The European Trade Union Federations^[1] and the European Trade Union Confederation will not support any institutional deal on the EC Talent Pool proposal. This reinforces our previous statements^[2], issued at every key moment of the legislative procedure. Two years on, the positions adopted by the European Parliament and the Council bring limited improvement. We therefore call for its withdrawal.

We would like to reiterate our support for migrant workers’ access to the EU labour market, provided that this is based on full respect for labour, trade union and social rights, with the same working conditions as EU nationals, including access to public services and social protection. 

The EC proposal and the positions of the two co-legislators offer no guarantees of this kind. We understand that the EC promotes this as merely a matching pool. However, much more must be done to secure decent labour and living conditions for migrant workers wishing to live and work in Europe before such a tool can be established. Even more so as many of the “shortage occupations” belong to labour intensive and fraud sensitive industries, such as construction, food, agriculture, hospitality and transport. These sectors are often characterised by low pay, poor and arduous working conditions, and precarious forms of employment. However, this issue is also becoming an increasing trend in other sectors, most notably in manufacturing, with the textile and shipbuilding sectors most affected. 

The solution to labour shortages lies primarily in improving pay and working conditions for all workers, including migrant workers already residing in the EU. 

The proposed Talent Pool will do nothing to curb the current level of exploitation of migrant workers. On the contrary, it risks legitimising malicious actors by giving them an EU stamp of approval. It will fuel more obscure intermediaries, placing workers in jobs whose quality is completely outside of the Pool’s scope. The positions adopted by co-legislators bring no substantial correction to these flaws.

These mainly consist in the loose definition of labour intermediaries as ‘other participating entities’, which will rubber-stamp fraudulent recruitment procedures, in its potential to encourage unscrupulous employment schemes in long subcontracting chains, in ignoring bogus posting risks in fraud-sensitive sectors as the so-called voluntary participation of Member States is an idle argument.   

We insist that the Talent Pool proposal is premature. The forthcoming Fair Labour Mobility Package, revision of the European Labour Authority’s mandate and the Quality Jobs Roadmap provide an opportunity to address the issues highlighted in this letter before embarking on such proposal. In this sense, we call for an EU Directive on subcontracting and labour intermediation; tackling abusive subcontracting and labour intermediation practices is essential to guaranteeing fair treatment and preventing labour exploitation through long and opaque chains.

Migrant workers and jobseekers must be able to expect decent working conditions and equal treatment. We cannot risk exposing migrant workers to exploitation and abuse through a flawed EU Talent Pool. 

We remain at your disposal for any further clarification.

Yours faithfully,

Giulio Romani
Confederal Secretary

[1]ETF, EFBWW, EFFAT, EPSU, IndustriALL Europe

[2]Talent pool will embed exploitation, ETUC-ETUFs Joint letter, ETUC Position on the EU Talent Pool