D2h3 - What is to be understood by “binding provisions”?

Binding provisions are public policy provisions which form the overriding mandatory rules of a State. They are provisions from which the parties to a contract may not derogate.

When the law of a particular State is applied, it is possible to give effect to the binding provisions of the law of another State with which the situation displays a close connection, if and to the extent to which, according to the law of the latter State, those provisions are applicable regardless of the law governing the contract.

Binding provisions are therefore those from which the law of a State does not allow any derogations by contract. They are provisions intended to ensure minimum protection for employees.

Also, the above-mentioned Regulation 593/2008 of 17 June 2008 (Rome I) makes it clear that overriding mandatory provisions are binding provisions with which compliance is felt to be crucial by a country in order to safeguard its public interests, such as its political, social or economic organisation, to such an extent that its application is required to any situation falling within its scope, regardless, moreover, of the law applicable to the contract.

It is to be noted that overriding mandatory provisions may differ from one States to another. Provisions relating to a written employment contract, to the social minimum wage, too working time, to the length of breaks, to daily and weekly rest, to paid holiday, etc. are, for example, among the Luxembourg overriding mandatory provisions.

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