Overcoming Barriers of Employee Ownership in France, Italy, Spain, the UK, and the US

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Purpose – The purpose of this paper is to give an updated overview over the development of employee-ownership in Italy, France, Spain including Mondragon, the UK, and the US with relatively many employee-owned firms. How has the barriers for employee-ownership been overcome in these countries?

Design/methodology/approach – The overview is based on updated descriptions of the development of employee-ownership included in this special issue. The analysis follows the structure of overcoming five barriers: the organization problem; the startup and takeover problem; the problem of entry and exit of employee-owners; the capital- and the risk problem.

Findings – Italy, France and Spain have overcome the barriers by specific legislation for worker cooperatives, this includes rules for entry and exit of employee members. Cooperative support organizations play an important role for monitoring and managing the startup problem and for access to capital. The Mondragon model includes individual ownership elements and a group structure of cooperatives. The EOT and ESOP models are well suited for employee takeovers, financing are eased by tax advantages, and they are all-employee schemes. While the EOT has no individual risks the ESOP model has the possibility for capital gains for employees but also the risk of losing these gains.

Originality/value – Comprehensive and updated overview of the development in employee-ownership in the five countries to identify successful formats of employee-ownership for implementation in countries with few employee-owned firms.
Original languageEnglish
JournalJournal of Participation and Employee Ownership
Issue number3
Pages (from-to)230-263
Number of pages34
Publication statusPublished - 2023


  • Employee-ownership
  • Institutional context for employee-ownership
  • Italy
  • France
  • Mondragon
  • Spain
  • UK
  • US
  • EOT
  • ESOP

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