Guide / Around the World
Global Reference · ILO & OECD data
Collective bargaining agreements around the world
The CBA is not an American invention or a North American habit — it is one of the most widespread labor institutions on Earth. The name changes at every border; the idea doesn't: a negotiated, binding rulebook between organized workers and their employers.
Same institution, different names
Search for the local term and you find the same document everywhere: recognition, wages, hours, seniority, dispute resolution, benefits. What varies is level (enterprise vs. sector vs. national) and extension (whether agreements legally cover non-signatory employers — the mechanism behind Europe's near-universal coverage).
| Country | What it's called | Coverage* | Notes |
|---|---|---|---|
| United States | Collective bargaining agreement (CBA) | ~10% | Enterprise-level; NLRA; multiemployer Taft-Hartley funds carry the pensions |
| Canada | Collective agreement / convention collective | ~30% | Federal + provincial codes; Rand formula dues checkoff |
| United Kingdom | Collective agreement | ~26% | Presumed "binding in honour only" unless stated — a famous legal quirk |
| Ireland | Collective agreement | ~34% | Registered agreements enforceable via the Labour Court |
| Australia | Enterprise agreement (EBA) | ~35–40% (EAs) | Fair Work Act; most other workers covered by industry awards |
| New Zealand | Collective employment agreement (CEA) | ~17% | Employment Relations Act 2000 |
| Germany | Tarifvertrag | ~50% | Sector bargaining (Flächentarifvertrag) + works councils |
| Netherlands | Collectieve arbeidsovereenkomst (CAO) | ~80% | Ministerial extension makes sector CAOs near-universal |
| France | Convention collective | ~98% | Extension by decree; coverage independent of low union membership |
| Belgium | Convention collective de travail / CAO | ~96% | National + sector joint committees |
| Austria | Kollektivvertrag | ~98% | Mandatory employer-chamber membership extends everything |
| Italy | Contratto collettivo nazionale (CCNL) | ~98% | National sector contracts set de facto minimum wages |
| Spain | Convenio colectivo | ~80% | Statutory erga omnes extension |
| Sweden | Kollektivavtal | ~89% | No statutory minimum wage — agreements do that job; Ghent-system unions |
| Denmark / Norway / Finland | Overenskomst / tariffavtale / työehtosopimus | ~80–90% | The Nordic model: bargaining as primary labor-market regulation |
| Brazil | Convenção / acordo coletivo de trabalho | High (sector) | CLT framework; annual sector conventions |
| Mexico | Contrato colectivo de trabajo | Reforming | 2019 labor reform + USMCA: legitimation votes replacing "protection contracts" |
| Argentina | Convenio colectivo de trabajo | High | Sector agreements with erga omnes effect |
| South Africa | Collective agreement (bargaining councils) | ~30% | Sectoral bargaining councils can extend agreements |
| Japan | 労働協約 (rōdō kyōyaku) | ~16% | Enterprise unionism; shuntō spring wage rounds coordinate outcomes |
| South Korea | 단체협약 (danchehyeobyak) | ~14% | Enterprise-level, growing sector experiments |
*Approximate share of employees covered by collective agreements; ILO/OECD-reported figures vary by year and method. OECD average: ~33% and declining since the 1980s everywhere extension mechanisms are absent.
What the differences teach
- Coverage is a policy choice, not a membership count. France has single-digit union membership and 98% coverage; the U.S. has higher membership share than France and one-tenth the coverage. Extension mechanisms are the difference.
- Where coverage is enterprise-level (North America, Japan, Australia), the agreement is operational. It names the employer, the classifications, the contribution rates — it can be administered directly. That's why North American CBAs generate pension funds, hour banks, and remittance machinery.
- Where coverage is sectoral (most of Europe), the agreement is regulatory. Administration lives in industry funds and statutory systems instead.
- Everywhere, the agreement is the source of operational truth — which is why reading it correctly matters on every continent.
Where we operate
The free AI analysis is available worldwide — if you have a collective agreement in English, French, or Spanish, from any country, we can read it and return the rule map. The fully operated AI pension & benefits service currently runs for organizations in the United States and Canada, where enterprise-level agreements and Taft-Hartley-style funds make it immediately deployable; the United Kingdom, Ireland, Australia, and New Zealand are next — get on the expansion waitlist.
From document to operation
Whatever your country calls it, we can read it.
Upload your collective agreement — CBA, EBA, CAO, Tarifvertrag, convention collective — and get a free AI-built rule map of every operational provision, reviewed by humans.