A common development among OECD and EU countries is the increase of temporary agency work in the last decade despite different regulatory regimes. For the researcher, agency work is an interesting topic as it is part of the romance of flexible working patterns, the new economy and a new type of employment arrangements; but is also part of a process that undermines employment conditions, collectivism and workers’ rights. Using Germany as an example of a country with a highly regulated temp industry and Australia as a country with very little regulation in this area, the paper outlines the growth and extent of agency employment in each country and examines the regulatory regime that applies in each country. The regulation of temporary agency work in Germany and Australia will be contrasted with the proposed legislation by the European Directive on temporary agency work in order to develop new proposals for an advanced supranational regulatory approach on temporary agency work. “The very essence of civil liberty certainly consists in the right of every individual to claim the protection of the laws”.
International Journal of Comparative Labour Law & Industrial Relations Vol. 23, Issue 3, p. 401-431