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What changed

From · Plenary report · 17 Dec 2025 A-10-2025-0269 with recommendations to the Commission on the 28th Regime: a new legal framework for innovative companies
To · Adopted text · 20 Jan 2026 TA-10-2026-0002 The 28th Regime: a new legal framework for innovative companies
✦ In short · AI narration of the differences below, generated 4 Sept 2026

The versions differ only in formal points and wording: terminology is aligned, references updated, and punctuation corrected. #1#2#3#4 Two changes affect substance: the condition for employee participation rules and the fallback trigger are rephrased, altering the circumstances under which they apply. #23#24

2 changes of substance, plus 18 formaland11 wording-only. Each change below carries a one-line ✦ note from the same model. Written from the two texts only — read the highlighted passages before relying on it.

The changes to the text itself, in document order. Cover page, citations (“having regard to …”), standard resolution paragraphs and punctuation-only edits are left out — they are in “Show every difference”.

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Change #23 Substance under “ANNEX TO THE RESOLUTION: RECOMMENDATIONS AS TO THE CONTENT OF THE PROPOSAL REQUESTED”

Changes condition from "provided that the legal order of the registered office does not provide for at least the same level" to "unless the legal order provides for at least the same level".

Regarding employee participation, the S.EU must be subject to the rules in force concerning employee participation, if any, in the Member State of the registered office. However, if an S.EU conducts an economic activity which entails employment in another Member State without setting up a branch, agency or subsidiary, the S.EU must be subject to the rules in force concerning employee participation, if any, in the Member State of the place of employment provided thatunless the legal order of the S.EU’s registered office does not provideprovides for at least the same level of board-level employee representation rights as required under the law of the place of employment. If necessary, the S.EU should adjust its Articlesarticles of Associationassociation accordingly.

Change #24 Substance under “ANNEX TO THE RESOLUTION: RECOMMENDATIONS AS TO THE CONTENT OF THE PROPOSAL REQUESTED”

Changes fallback trigger from "where an S.EU has not yet introduced employee participation or where reaching the threshold implies changes" to "provided that an S.EU has not yet introduced employee participation or provided that reaching the threshold implies changes".

Where the applicable law cannot be determined in accordance with the principles set out in the previous paragraph, as a fallback option,option a negotiation procedure equivalent to that provided for in Articles 3 to 7 of Directive 2001/86/EC must be initiated once the number of employees reaches in at least one Member State any threshold triggering board-level employee representation rights in that Member StateState, whereprovided that an S.EU has not yet introduced employee participation or whereprovided that reaching the threshold implies changes to the existing employee participation.