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.

Each of the six countries uses a different approach, although there are many similarities. The US employee stock ownership plan (ESOP) is part of retirement plan law and provides employees with substantial tax incentives to sell stock to an ESOP funded by the company. Employees accumulate an equity interest in the company and cash in their accounts after terminating employment. In the UK, employee ownership trusts (EOTs) do not provide employees with an equity stake; instead, the EOT holds the shares permanently, while the company shares profits or dividends with employees. The UK offers a 50% tax exclusion for sales to qualifying EOTs. Canadian EOTs are similar to those in the UK and also receive tax incentives, but companies can optionally incorporate equity claims for employees. The Slovenian and Danish models create an employee-owned company (EOC) to acquire a partial or complete ownership interest in an operating company whose shares are sold to the EOC and financed primarily or entirely by the operating company. Both also provide tax incentives for sellers. The French model is more of a hybrid approach, with elements of employer contributions and possibilities for employee share purchases.

While the US, UK, Canadian, Slovenian, and Danish models are intended to be used primarily by closely held companies for business transition, the French model generally provides minority ownership for employees in larger companies and often is part of the required profit-sharing contribution for companies with more than 50 employees.  The Slovenian and Danish models combine elements of worker cooperatives, EOTs, and ESOPs, emphasizing employee governance rights more strongly than any of the other models.

The paper was authored by NCEO founder Corey Rosen; Graeme Nuttall, the international ambassador for the UK Employee Ownership Association and the author of the Nuttall Report, which led to the UK’s EOT legislation; Jon Shell, the chair of Social Capital Partners in Canada; Thibault Mirabel, the head of research at Equalis Capital and vice-chair of Capital Collectif in France; Tej Gonza, the cofounder and director of the Inštitut za ekonomsko demokracijo (IED) in Slovenia; and Thomas Poulsen, associate professor of corporate governance at the Department of Accounting at Copenhagen University.