EoR vs portage vs umbrella vs PEO
A side-by-side reading of the main triangular employment schemes in Europe and North America.
The Employer of Record is often confused with neighbouring schemes. Each has its own legal basis, its own permitted business model and its own degree of worker autonomy.
Overview
All these schemes share a triangular logic: a worker, a legal employer (or facilitator) and an end user. They differ on three axes: the statute that frames them, the autonomy left to the worker (especially for client acquisition), and the permitted assignment duration.
Comparison table
| Scheme | Country | Dedicated statute | Worker autonomy | Typical duration |
|---|---|---|---|---|
| EoR (Luxembourg) | LU | No (common law) | Low (client supplies the work) | Months to a few years |
| Portage salarial | FR | Yes (L.1254-1 s.) | High (worker prospects clients) | Up to 36 months / client |
| Umbrella company | UK | No (sectoral practice) | Variable (recruiter-driven) | Per assignment |
| PEO | US | Co-employment doctrine | N/A — outsourced HR | Permanent |
| Arbeitnehmerüberlassung | DE | Yes (AÜG) | Low | Up to 18 months / client |
| Intérim | LU | Yes (L.222-1 s.) | Low | Limited motives |
French portage salarial
Codified in articles L.1254-1 et seq. of the French Labour Code, portage salarial is a triangular relationship in which a senior consultant prospects clients and the portage company employs them and invoices the client. It is reserved to qualified missions (typically a minimum hourly rate, autonomy in client acquisition).
UK umbrella company
UK umbrella companies are not statutorily defined. They emerged in the recruitment industry to employ contractors who would otherwise operate as personal service companies. Since the IR35 reforms, umbrella employment has become a frequent compliance fallback for off-payroll workers.
US PEO
The Professional Employer Organization rests on a co-employment doctrine: the PEO and the client share employer responsibilities. It is primarily a domestic HR-outsourcing model for US small businesses, with the PEO carrying payroll, benefits and compliance. It differs structurally from international EoR setups.
German Arbeitnehmerüberlassung
The German Arbeitnehmerüberlassung is governed by the AÜG (statute on labour leasing). It requires a licence and caps assignments at 18 months per user company, with equal-pay obligations after nine months.
Luxembourg intérim
Luxembourg intérim (temporary agency work, articles L.222-1 et seq.) is the closest domestic vehicle to an EoR setup. It requires the temporary agency to be authorised and limits assignments to specific motives. A licensed agency is the most robust legal vehicle for an EoR-style arrangement in Luxembourg.