"In this discussion paper we argue that occupational safety and health (OSH), and more specifically the failure to respect OSH rules and regulations, is to be considered an essential part of the concept of undeclared work sensu lato and the fight against it. Before the COVID-19 pandemic this was all too often overlooked by most if not all stakeholders involved: policy makers, public authorities, social partners, scholars, etc. That is why we strongly recommend a review and a clarification of the relationship between competent administrations and inspectorates at both a national and European level (e.g. through the European Labour Authority - ELA). Furthermore, in policy circles, the reasoning could be that during the COVID-19 pandemic and its aftermath, the fight against undeclared work, including infringements of OSH, should not be a priority, or that enforcement may be less stringent. We argue that such choices have negative consequences, bearing in mind that there are strong indications that the evolution of undeclared work is counter-cyclical. Consequently, the pandemic is no reason to ‘cut' individuals and businesses ‘some slack' when it comes to infringements of tax and social law."

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