This discussion paper examines how Brexit has reshaped transnational labour governance by focusing on European Works Councils and Societas Europaea Works Councils as institutions embedded in multi-level European employment relations. Building on debates in neo-institutional theory, the paper develops an integrative set of analytical considerations that relates insights from Historical, Rational Choice, Sociological, and Discursive Institutionalism, with Historical Institutionalism serving as the primary point of reference. Conceptually guided by an interpretive literature review, the analysis approaches Brexit as a critical juncture unfolding through temporally distinct yet interconnected phases of institutional transformation. It highlights how adaptation may proceed through mechanisms such as drift, layering, and conversion, while also drawing attention to intercurrence, exogenous gradualism, and the potential for institutional innovation under conditions of legal ambiguity and contested legitimacy. By mapping key actor constellations, the paper foregrounds how asymmetries in strategic resources, normative claims, and discursive power shape post-Brexit reconfigurations of participation, membership, and authority within transnational works councils. Overall, the paper offers analytical points of reference for understanding institutional continuity and change in transnational employment relations and for examining comparable cases of cross-border institutional restructuring under sustained uncertainty.
Frisone et al. (Thu,) studied this question.