In the area of free movement of workers in the European Union, the concept of worker is of particular importance as it grants Union citizens a right of residence in a Member State and access to its non-contributory social security benefits. However, reports and studies have shown that the criteria developed by European jurisprudence regarding the "concept of worker" are interpreted narrowly by many Member States, especially with regard to "an activity of economic value". This trend is also visible in Germany, where the competent national authorities, the Job Centres, often do not recognise the status of a worker in the case of EU citizens with a low salary or a low weekly working time and therefore deny access to basic security benefits for jobseekers.

The aim of this dissertation project is to evaluate the regulations of selected Member States on the basis of a legal analysis and expert interviews. On this basis, it will be examined whether Member States with similar regulations also have similar problems or, if not, why this problem does not occur there. Furthermore, it will be examined why Member States with stricter regulations consider them necessary and whether these regulations can also be implemented in Germany.