Global Reference Tool

ELI & Employee Transfer
Obligations Compared

A verified, source-cited comparison of employee liability information and transfer obligations across the UK, Ireland, EU, UAE, Saudi Arabia, and Qatar — built for FM professionals managing international contract transitions.

Primary sources verified

11 authoritative citations

6 jurisdictions

Important: This comparison is for educational purposes only and does not constitute legal advice. Employment law changes frequently. Always seek qualified legal counsel for specific transactions. Data current as of April 2026.

Filter jurisdictions:

Criterion	🇬🇧 United Kingdom TUPE 2006 (SI 2006/246)	🇪🇺 European Union Acquired Rights Directive 2001/23/EC	🇮🇪 Ireland S.I. No. 131 of 2003 (as amended)	🇦🇪 UAE (Mainland) Federal Decree-Law No. 33 of 2021	🇸🇦 Saudi Arabia Labour Law — Royal Decree No. M/51	🇶🇦 Qatar Labour Law No. 14 of 2004 (as amended)
Automatic Transfer of Employment Do employment contracts transfer automatically to the new employer without requiring new contracts?	Yes Yes — full automatic transfer	Yes Yes — via member state law	Yes Yes — full automatic transfer	No No — new contracts required	Partial Partial — going concern only	Partial Partial — going concern only
Employee Liability Information (ELI) Is there a statutory obligation to provide detailed employee data to the incoming employer before transfer?	Yes Yes — Regulation 11	Varies Member state discretion	No No — information to representatives only	No No statutory obligation	No No statutory obligation	No No statutory obligation
Minimum Notice Period What is the minimum statutory notice period before the transfer must be notified?	Yes 28 days before transfer	Varies 'Good time' — varies by state	Yes 30 days — where reasonably practicable	Partial Contractual notice only	Partial Contractual notice only	Partial Contractual notice only
Consultation Requirement Is there a statutory obligation to consult with employee representatives before the transfer?	Yes Yes — Regulation 13	Yes Yes — Article 7	Yes Yes — Regulation 8(4)	No No statutory requirement	No No statutory requirement	No No statutory requirement
Dismissal Protection Are employees protected from dismissal where the sole or principal reason is the transfer itself?	Yes Yes — Regulation 7	Yes Yes — Article 4	Yes Yes — Regulation 5	Partial Limited — contractual only	Partial Limited — Labour Law only	Partial Limited — Labour Law only
Inherited Liabilities Does the incoming employer inherit the outgoing employer's historical employment liabilities?	Yes Yes — full inheritance	Yes Yes — full inheritance	Yes Yes — full inheritance	No No — fresh start	Partial Partial — EOSA transfers	Partial Partial — gratuity transfers
Collective Agreements Transfer Do collective agreements in force with the outgoing employer transfer to the incoming employer?	Yes Yes — transfer with employees	Yes Yes — minimum 1 year	Yes Yes — transfer with employees	No Not applicable	No Not applicable	No Not applicable
End of Service / Redundancy How are accrued end-of-service benefits or redundancy entitlements handled on transfer?	Yes Statutory redundancy transfers	Varies Varies by member state	Yes Continuity preserved — redundancy transfers	Partial Gratuity resets on transfer	Yes EOSA transfers with employee	Yes Gratuity transfers with employee
Penalty for Non-Compliance What is the statutory penalty for failing to comply with transfer obligations?	Yes Up to 13 weeks' pay per employee	Varies Member state sets penalties	Yes Up to 2 years' remuneration	Partial Contractual damages only	Partial Labour Court — contractual damages	Partial Ministry of Labour — fines
Written Format Required Must notifications and information be provided in writing?	Yes Yes — written or readily accessible	Varies Not specified at EU level	Yes Yes — written where no representatives	Partial Compulsory in DIFC only	Partial Best practice — not mandated	Partial Best practice — not mandated

Yes — obligation exists

No — no equivalent obligation

Partial / Varies — conditional or member-state dependent

Click any row to expand detailed notes

Key Insights for FM Professionals

What this comparison means in practice when managing international contract transitions.

🇬🇧

UK has the most prescriptive regime

TUPE 2006 is one of the most detailed employee transfer frameworks globally. The 28-day ELI obligation, automatic transfer, Reg 7 dismissal protection, and per-employee penalties create a highly structured — and highly litigated — environment. FM managers must treat TUPE as a core mobilisation workstream, not an HR afterthought.

🇪🇺

EU sets the floor — member states vary widely

The Acquired Rights Directive guarantees automatic transfer and consultation rights across all 27 member states, but the detail varies significantly. Germany's works council rights, France's pre-transfer consultation obligations, and Ireland's 30-day notice period all differ. Always check national implementation law for cross-border FM contracts.

🌍

Middle East: no automatic transfer on mainland

UAE, Saudi Arabia, and Qatar do not have a TUPE equivalent for most asset transfers. Employees must be individually re-engaged, visas reissued, and gratuity settled. This creates significant cost and timeline risk in FM mobilisations. DIFC (Dubai) is the exception — automatic transfer applies within the free zone.

This comparison was compiled by MCFM Global Academy for educational purposes. It does not constitute legal advice. Data verified April 2026. For legal advice on specific transactions, consult a qualified employment lawyer in the relevant jurisdiction.

Need to train your team on TUPE and international transfer obligations?

MCFM Global Academy provides structured, practical training for FM professionals managing mobilisation and contract transitions.