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On 9 July 2026 in case C-768/24 (Hortis), the European Court of Justice ("ECJ") ruled that mandatory law of the country where an employee habitually works does not automatically govern the employment relationship. Where, based on an overall assessment, the employment relationship is more closely connected with another country, the law of that country may apply instead, even where that law is less favourable to the employee. This principle applies regardless of any choice of law agreed between the parties.
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