Abstract

This study provides a comparative overview of labour regulation in Germany and Kazakhstan with a focus on collective bargaining systems and emphasizing key differences and similarities considering the historical, economic and social background of the two countries.
Much has been written about the German industrial relations system in English. However, Kazakhstan’s collective labour relations are basically still unknown to international scholars. There are few sources that describe the Labour Law of Kazakhstan in English, and most of them are dedicated to specific areas of labour relations.
Evidently, the most important way to achieve a better understanding of any national legal system is a comparative legal analysis along with historical perspective, comparing to the well-known legal system with long-term traditions and presenting a classical model of labour regulation.
This contribution also sheds light on the recent reforms in labour regulation in both countries that significantly affect the contours of modern Collective Labour Law.
It concludes that the German collective bargaining system is decentralized with a predominant sectoral level and bilateral structure of social partnership, while Kazakhstan has a centralized collective bargaining system with a predominant national level and tripartite structure of social partnership.