"This article discusses the factors that influence the transferability of different types of occupational safety and health (OSH) economic incentives from one country to another, based on data collected by the European Agency for Safety and Health at Work (EU-OSHA) by means of a survey among EU member states and a literature review of relevant reports, articles and databases. Despite the wide differences in Europe's social security systems, a high degree of similarity was observed between the countries regarding the basic system design criteria. When it comes to insurance incentive schemes, the fundamental difference between countries is whether the workers' compensation scheme is based on a competitive market between private insurance companies or a monopoly structure adopted by 19 of the 27 EU member states. Subsidy systems, tax incentives, and insurance-based incentives are theoretically possible in all EU countries. Implications are discusseed."

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