Corey Rosen
Updated NCEO Paper Compares Employee Ownership Models in Six Countries
Updated February 23, 2026
A newly updated NCEO paper, Expanding Employee Ownership: Models in the US, UK, Canada, France, Slovenia, and Denmark (PDF; also see the embedded version below), explores the six leading models for trust-based or similar collectively based employee ownership. (The original paper, released in May 2025, covered the first five countries; the revised version adds Denmark and makes minor updates elsewhere.) Research and experience show that holding employee ownership in a trust or similar vehicle rather than having employees individually own shares tends to be the most sustainable form of employee ownership. Companies and/or sellers also need tax or other incentives to create and fund the plans for employee ownership to grow. Finally, employee ownership is more likely to be widely adopted when plans are funded in whole or largely by the company, rather than just by employees. These six models are the only legislatively supported models that combine all these features. The U.S. model was enacted in 1974, the U.K. model in 2014, Canada in 2024, Slovenia in 2025, and Denmark in 2026. The French program is based on a series of laws going back to the 1960s and amended over the years.
