The Value of Care: Brokering Work Conditions and Wages within a Transnational Care System

Abstract

This article explains how the triadic brokering system in the European Union affects the conditions of work and pay of mobile care workers. Using original survey data gathered from Polish care workers in Germany, the authors found that workers earn less money the more hours they work. Based on qualitative interviews with care workers and representatives of labor market intermediaries, they argue that the brokering relationship is responsible for the misalignment between working hours and pay. Workers negotiate their pay and working hours within two distinct contexts: in the domestic sphere with their German clients (care recipients and their families) and in interactions with care agencies in Poland. The article also identifies the conditions under which workers are able to benefit from, or are disadvantaged by, the brokering relationship. Findings suggest that these consist of a combination of individual (e.g., language proficiency, professional care skills) and structural conditions (e.g., demographic changes, EU mobile rights).

The European Commission’s (2022) European Care Strategy directs attention to the problem of extremely poor working conditions—including bogus employment and very low wages—endured by Europe’s predominantly female and migrant domestic care workforce, an issue that existing regulations have insufficiently addressed. Despite extensive evidence of dire employment conditions and labor exploitation in the care sector (Yeoh and Huang 2010; Bahna and Sekulová 2019; Uhde 2026), there remains a lack of knowledge about migrants’ ability to negotiate, including their ability to arrange remuneration appropriate to their working time.

The transnational care system in European countries is becoming increasingly dependent on the services provided by specialized private care brokers. This has led to a need to reconceptualize the connections between care workers and their clients (Paul 2017; Chau 2020). While there is growing interest among researchers in the impact of private labor market intermediaries on employment relations (Bidwell and Fernandez-Mateo 2008; Alberti and Sacchetto 2024), there has been little scholarly debate about employees’ bargaining power and its effect on working conditions (Sauer, Valet, Shams, and Tomaskovic-Devey 2021; Szytniewski and van der Haar 2022).

In this study, we focus on the working conditions of Polish, female, live-in care workers engaged through private brokers for work in elderly care positions in Germany as an illustrative case of intermediated labor mobility within Europe (Danaj and Meszmann 2024). Examining brokered employment relationships in that transnational mobility regime, we can observe the projectification of care work. By “projectification” we understand a work model based on the implementation of defined tasks and the achievement of specific goals within a specified time frame. This model requires individuals to be flexible, adaptable, and self-disciplined (Schneider 2024). As a result, employee remuneration is likely not to correlate with the number of hours worked. Thus, we address two questions: What role do brokering agencies play in setting wage arrangements in the live-in elder care sector? And under what conditions are workers able to benefit from, or are disadvantaged by, the brokering relationship?

To answer these questions, we use original survey and in-depth interview data from care workers and representatives of private labor market intermediaries. First, using a quantitative approach, we show that mobile live-in care workers who report working more hours receive lower wages. To explain this puzzle, we examine existing research on wage-setting and the bargaining position of mobile workers to more clearly elucidate the individual and structural factors influencing remuneration mechanisms in transnational care. Our qualitative data enable an analysis of how the triadic brokering system facilitated by the established and expanding EU Posting of Workers Directive (Leiber and Rossow 2021) shapes the working conditions and wages of mobile, live-in care workers. We augment our original data with previous research that relied on small samples and qualitative studies (Kniejska 2018; Cojocaru and Rosińska 2021).

Our contribution is to the literature strands on private labor market intermediaries and on mobile workers and their bargaining power. We uncover wage-setting mechanisms in brokered employment relations by highlighting how the interplay between client–worker and worker–agency negotiations affect power dynamics and workers’ outcomes. This literature has made inconsistent findings in respect to the bargaining power of mobile workers (Hopfgartner, Seubert, Sprenger, and Glaser 2022), with some studies arguing that their ability to negotiate employment conditions is limited (Martin 2017; Weeraratne 2021) and others suggesting that they have a relative advantage over non-EU migrants (Ewers, Gengler, and Shockley 2021). Our conclusions may therefore extend beyond the case at hand and complement research into the impact of private labor market intermediaries on the employment conditions of workers in other labor-intensive, low-wage, and non-unionized sectors (e.g., agriculture, food processing, construction, cleaning, platform work). We also expand academic discussion on mobile workers’ bargaining power by identifying factors influencing workers’ bargaining power in brokered employment relations (Meardi 2012). As our analysis shows, in the context of acute labor shortages and fierce competition for workers, private brokering agencies in Europe are willing to make concessions to meet employee expectations (Matuszczyk and Bojarczuk 2024). Moreover, formal skills (such as language proficiency) positively influence workers’ bargaining powers vis-à-vis agencies.

Wage-Setting in Migrant Domestic Care Work

The theoretical starting point of this article is a strand of research on wage-setting arrangements in the context of the de-standardization of work and the individualization of labor contracting (Michelacci and Suarez 2006; Säve-Söderbergh 2019; Alberti and Sacchetto 2024). The literature distinguishes two wage-setting mechanisms: wage posting and wage bargaining (Michelacci and Suarez 2006; Brenzel, Gartner, and Schnabel 2014). The former refers to a system in which employers define the terms of employment in advance and set salaries ex ante, limiting the negotiating power of potential employees. Germany is a good example of this model (Brenzel et al. 2014), which is common in the public sector, large companies, and in part-time and fixed-term employment contracts (Sauer et al. 2021). Conversely, in a wage-bargaining system, initial offers are generally made by employers, but job candidates can make counteroffers and try to influence the final terms of their contract (Zwysen 2024). However, not all job candidates are in a position to make demands at the wage-bargaining stage. Those who have higher education, permanent jobs, or special qualifications will have more negotiating power than unskilled applicants or those with a low level of education (Brenzel et al. 2014). Studies also suggest that women and migrant workers have weak negotiating power (Säve-Söderbergh 2019; Sauer et al. 2021).

In light of these findings, the literature on migration and labor mobility has focused on the frail bargaining position of foreign care workers in host countries (Yeoh and Huang 2010; Ewers et al. 2021; Alberti and Sacchetto 2024). A substantial body of research has identified individual and structural factors contributing to low bargaining power, including insufficient language proficiency, low awareness of applicable legislation, lack of familiarity with cultural norms, the high prevalence of informal employment, poor access to worker support organizations, and the transient nature of migration status (Rye and Andrzejewska 2010; Meardi 2012; Faist 2019; Alberti and Sacchetto 2024). Weeraratne (2021) argued that where labor migrants have insufficient information about their legal status and the role they are applying for, their capacity to negotiate wages and incentives is significantly inhibited. This circumstance is particularly true for newly arrived migrants who may lack social networks and familiarity with the local labor market. Ewers et al. (2021) suggested that socioeconomic circumstances in countries of origin may also influence migrant workers’ ability to negotiate their wages. Some workers, such as European Union citizens, face minimal formal barriers to employment abroad. As a result, they may be able to utilize “voting by foot” (Meardi 2012)—meaning changing employers in search of more favorable working conditions—in negotiations over pay and conditions.

The ability to negotiate wages has also been shown to be associated with the characteristics of a given occupation, the implementation of minimum wage regulations, and the degree of worker unionization (Seiffarth 2023; Zwysen 2024). The absence or ineffectiveness of these mechanisms in low-wage, labor-intensive sectors, such as domestic care work (Yeoh and Huang 2010; Benoit and Hallgrimsdottir 2011), means that wage bargaining is much more individualized (Seiffarth 2023). Folbre and Smith (2017) highlighted the complexity of determining a satisfactory wage rate in domestic care work, largely because of the intrinsic motivations of workers and the difficulty of demonstrating the value of this type of work. The informal nature of care work provision (typically in private homes, often in confined spaces) further limits the bargaining power of care workers (Benoit and Hallgrimsdottir 2011; Chau 2020; Cojocaru and Rosińska 2021). In the context of severe labor shortages, employers may be more willing to meet workers’ demands to attract potential applicants (Backes-Gellner and Tuor 2010). This willingness may be particularly true in the elderly care sector in EU countries. However, a comprehensive understanding of the individual and structural factors influencing wage-setting in the EU transnational care sector is still to be developed.

Brokered Employment Relations in the Domestic Care Sector

The brokering of employment relationships is a distinctive feature of the transnational care sector and likely plays a key role in wage-setting dynamics. Over the past decade, scholars have recognized the global emergence of employment relationships in which a third party plays a primary role in facilitating and establishing work arrangements (Martin 2017; Schneider 2024). Intermediaries have been credited with the deregulation of the conventional labor market and traditional norms, the fostering of project-based work, and the spread of employment flexibility (Bidwell and Fernandez-Mateo 2008; Paul 2017). By taking over human resource management for their clients (i.e., employers in dyadic relationships) and offering professional, tailor-made solutions, labor market intermediaries increase their bargaining power within new, triadic (or brokered) employment relations (Szytniewski and van der Haar 2022). As a result, the distinction between employers and employment agencies is becoming blurred, as confirmed by, among others, the establishment of private care agencies in the transnational domestic care sector in the EU countries (Chau 2020; Nowicka, Bartig, Schwass, and Matuszczyk 2021).

The existing literature assessing the impact of brokers on the position of mobile workers highlights how broker resources (knowledge, money, contacts) allow workers to explore the global labor market and find legal employment in various sectors (Paul 2017; Mense-Petermann 2020; Matuszczyk and Bojarczuk 2024). By comparison, dependency on intermediaries might weaken worker agency and lead to exploitation and noncompliance (e.g., labor exploitation, debt bondage, wage theft; see Jones 2021; Weeraratne 2021). Researchers in Asia point to deepening power imbalances in the labor market, resulting in the spread of the “intermediary trap” for low-skilled workers (Xiang 2013). Similar research in Europe is scarce, and there is a lack of understanding of how brokers impact the bargaining positions of mobile workers in the European Union (Chau 2020; Szytniewski and van der Haar 2022; Danaj and Meszmann 2024).

The role of commercial intermediaries in the domestic care market in Europe is expanding (Bahna and Sekulová 2019; Nowicka et al. 2021; Uhde 2026). One example of this shift is illustrated by the appearance over the past two decades of brokered employment relationships in the elder care sectors in Austria, Switzerland, the Netherlands, and Germany (Horn, Schweppe, Böcker, and Bruquetas-Callejo 2019; Steiner, Prieler, Leiblfinger, and Benazha 2019; Chau 2020), which has been linked to regulations facilitating the free movement of services, in particular the EU Posting of Workers Directive. In this context, scholars have observed the replacement of bilateral relationships in domestic care based on a moral contract (Näre 2011) with a new model of industrial relationships built on labor productivity and efficiency (Marchetti, Geymonat, and Di Bartolomeo 2022). A conflict therefore emerges between the values of domestic care work, grounded in warmth and empathy fostered during daily interactions in the domestic space (Benoit and Hallgrimsdottir 2011; Cojocaru and Rosińska 2021), and the values of work regulated by a service contract and managed by an external actor. The involvement of commercial entities in the care relationship also results in alterations to daily interactions and the way services are determined by employers (who, in the new configuration, resemble care managers) (see Ambrosini 2015). Intermediary companies sell their services to families with dependents as an alternative to employing carers informally, offering a “care project” tailored to their expectations and taking over tasks related to employee management (Ambrosini 2015). Existing research suggests that mobile workers may either benefit or be disadvantaged by these arrangements (Matuszczyk 2021; Uhde 2026), but empirical evidence is still insufficient to address the question of workers’ wage-bargaining capacities within this new care model.

Transnational Elder Care System between Poland and Germany

Transnational domestic elder care between Poland and Germany offers a clear illustration of the broad phenomenon of intermediated mobility from Central and Eastern European countries (Danaj and Meszmann 2024; Uhde 2026). An estimated 300,000 households in Germany employ a foreign care worker, with the overwhelming majority being from Poland (Matuszczyk 2021). Given that these workers commute between countries on a regular basis, the same estimate suggests a total of 700,000 transnational care workers. The high demand for round-the-clock care services in Germany and the country’s well-developed migration infrastructure of private intermediaries facilitating the employment of mobile workers from Poland are key factors explaining this phenomenon.

Statistically, 22.4% of Germans are aged older than 65 and 7.2% are over 80 (Statistisches Bundesamt 2023), ranking Germany in the top five oldest societies in the European Union. An estimated 5.7 million people in Germany need care and four out of five receive it at home from their relatives (Statistisches Bundesamt 2024). When these unpaid family caregivers are unavailable, both legally employed and “grey market” carers from abroad step in (Leiber and Rossow 2021). Germany is de facto tolerant of undeclared care labor and refrains from workplace inspections in homes (Palenga-Möllenbeck 2024). German social policies also favor home-based care: Since 2017, cash benefits paid for home-based care have increased by 24% while state support for institutional-based care has stagnated (Horn et al. 2019). Since September 1, 2022, only nursing homes that pay their staff according to collective agreements are allowed to operate; this has caused the co-payment for institutional care to rise significantly, motivating families to begin informally employing live-in carers.

Since the early 2000s, Poland has become the largest provider of live-in elder care workers in EU countries (Nowicka et al. 2021; Kocher 2024). The number of corporate actors replacing informal middlemen in this field is steadily increasing (Horn et al. 2019), but no data yet estimates their share of the market. Leiber, Matuszczyk, and Rossow (2019) described a new collaboration model in which German brokerage agencies take responsibility for customer relationships in Germany. Open positions are forwarded to Polish sending agencies that recruit and employ local labor in Poland (thus setting wages) and then offer care worker portfolios to their German counterparts (Neumann and Hunger 2016). It should be emphasized that under EU law, placement services are free of charge for employees.

These sending agencies apply different legal models based on self-employment (in Poland or Germany), Polish civil law, or foreign labor law (Marchetti et al. 2022; Kocher 2024). Moreover, agencies differ significantly in competitive strategy, size, and approach to economic financial and legal risk (Palenga-Möllenbeck 2024). For example, some have close contact with client households and families and maintain social relations with care workers (i.e., family-run care agencies) while others have the size, experience, and power to dictate financial and legal conditions to their contracted carers (on corporate-style care agencies; see Leiber et al. 2019). Thus, carer working conditions can differ significantly depending on the strength of the relationship with the employer, the intermediary, and the type of agreement in place (Neumann and Hunger 2016).

Many brokering agencies operating in Germany advertise 24-hour care, although their webpages usually include a disclaimer that work around the clock “is prohibited by the German Working Hours Act” (Kocher 2024). Such advertisements do not mention remuneration for “on-call duty around the clock,” which implies this is included in the live-in arrangement (Neumann and Hunger 2016). At the same time, as Chau (2020) suggested, some employment agencies consider work and leisure time as inseparable for live-in elder care and thereby legitimize extensive working hours. Notably, live-in care workers employed on civil law contracts (mainly “contracts of mandate”) are free to arrange their working hours according to agreed job responsibilities based on the needs of the care recipient (Marchetti et al. 2022).

Brokers present work in transnational elder care as an optimal alternative to unemployment in host countries; they appeal in particular to retired and middle-aged women who face ageism and sexism in the labor market (Dingemans, Henkens, and van Solinge 2017; Bahna and Sekulová 2019; Uhde 2026). The decision to accept live-in care jobs abroad was found to be motivated by factors including divorce, widowhood, low pensions, the need to support adult children, and other financial obligations (Matuszczyk 2021). These circular workers from Poland are seen as docile, hard-working, attached to the households they serve, and willing to provide care—qualities that are utilized by care agencies in their marketing strategies (Palenga-Möllenbeck 2024).

Sample and Analytical Strategy

This article reconstructs the perspectives of workers, experts, and care agencies using interview and survey data generated through two projects.

The first project, “Domestic care for older adults during the pandemic: Impacts of COVID-19 pandemic-related travel restrictions on families in Germany and caregivers from Eastern Europe,” was initiated in April 2020 in response to COVID-19 pandemic-related restrictions affecting travel between Poland and Germany and was intended to shed light on how those restrictions impacted the provision of elder care. The project’s first module comprised an online survey of Polish elder care workers in Germany, and the second module surveyed the German households of elder care receivers. Web-based respondent-driven sampling (Wejnert and Heckathorn 2008) was initially used to recruit survey respondents. However, although the recruitment strategy began with highly motivated and well-connected care workers as seeds, this proved inefficient, generating only 12 responses over five weeks. Subsequently, the recruitment strategy was changed to the less restrictive snowball sampling approach (Biernacki and Waldorf 1981; Heckathorn 2011) but continued to track links forwarded from one research participant to the next. For better distribution, the survey was advertised through relevant mailing lists, online forums, Facebook groups, and Facebook advertising. The survey was online between October 20, 2020, and February 28, 2021. A total of 279 people completed the survey: 146 respondents were recruited through Facebook advertising, 40 were invited by other participants, and 93 were recruited through other channels such as posts in Facebook groups (74) or contacts in brokering agencies. An examination of the distribution of various characteristics within these recruitment groups revealed only minor differences (see Appendix Table A.1). Hence, it cannot be assumed that fundamentally different subpopulations were reached through the various recruitment methods. The survey included questions relating to transnational mobility while pandemic travel restrictions were in place (March–June 2020), length of assignment in Germany, contractual situation, qualifications, tasks performed, income, and working and leisure time for the year preceding the pandemic (March 15, 2019, to March 15, 2020). Survey questions also specifically asked how working hours, leisure time, and income had changed as a result of the pandemic.

Since there is a shortage of detailed information on Polish care workers in Germany, the values shown below can be interpreted as minimum values but not as representative proportions. All statements made here apply only to the persons surveyed; any generalizations should be made with caution. The bias of the sample is uncertain. However, considering the basic sample characteristics, there is little evidence for large bias as the distribution of characteristics such as age, gender, or income do not differ significantly between recruitment methods. Additionally, the age distribution (mean and median at approximately 56 years old) and the proportion of women (93.5%) in our survey are close to the corresponding values of other studies (Petermann, Jolly, and Schrader 2020). However, 89.6% (250) of respondents reported having a written contract. ¹ Most respondents (204) reported having a contract with an agency operating in Poland. Approximately 56% (156) reported being engaged to undertake temporary employment in Germany. These percentages match rough estimates by Steiner et al. (2019), according to which approximately 70% of agencies use posting. At the same time, 240 respondents reported being temporarily replaced by a care worker without a contract. This finding could indicate a bias toward contractual workers. Either the survey did not sufficiently reach care workers without a contract and therefore only showed the situation of care workers employed with a contract, or surveyed care workers regularly change their employment situation, as suggested by qualitative studies (Kniejska 2018).

On average, respondents had been working as carers in Germany for 7.5 years. The carer with the longest service had been working in this field since 1981 (approximately 39 years), while nine respondents began working as recently as 2020. Age and length of service did not correlate significantly. The age of care workers ranged from 27 to 80 (the average being 56). In the 12 months prior to the pandemic, respondents had been working in Germany for an average of 7 months, which fits well with the alternating type of work assignments (Kniejska 2018). ²

The second project was part of Matuszczyk’s research on the mobility regime that developed in Poland in the 1990s. ³ Starting in July 2018, Matuszczyk interviewed various institutional actors involved in the domestic care industry with the aim of understanding transnational domestic care policy regulation and its implications. The main group of actors interviewed comprised owners and representatives of private labor market intermediaries (i.e., care agencies) with whom we conducted 17 expert interviews between 2018 and 2023. They were purposely selected for the sample on the basis of at least two years of activity in the care industry posting Polish employees to Germany. Additionally, live-in domestic care workers commuting between Poland and Germany were interviewed between October 2020 and May 2023. The care workers recruited for the interviews had to have worked in Germany for a minimum of one year. Recruitment proceeded by snowballing from three initial contacts who were very active on social media and who acted as gatekeepers. Data saturation was reached after 35 in-depth interviews. Given the COVID-19 pandemic and related restrictions, in-depth interviews with care workers were conducted remotely by telephone, Skype, or Messenger. This method facilitated interviews with care workers who were living with care receivers and performing care work in Germany at the time of the interview. Regardless of circumstances, interviews lasted more than an hour on average (with a range of 35 to 120 minutes). The interview script included questions on commuting during the pandemic, arrangements with current and past agencies in Poland, and the work itself, including the balance between work and leisure time. All interviews were audio recorded with informed consent and analyzed using Nowell, Norris, White, and Moules’ (2017) thematic analysis method.

Earning Less When Working More: Survey Results

The survey data offer a good overview of working hours and compensation. The results paint a picture of difficult and demanding domestic care work. Apart from a few extreme values, the number of daily working hours varied between 6 and 15 with a mean value of 11. The duration of daily free time varies similarly. Here most care workers reported having between 0 and 4 hours of leisure time, defined as time when they do not work or sleep. Most respondents reported having two hours of free time per day (see Figure 1). Of the respondents, 57 reported having to get up regularly during the night to care for care recipients, and 217 respondents indicated that they did not have to do this.

Figure 1.

Daily Work and Leisure Time in Hours

Approximately 65% of surveyed care workers earned a monthly net income between €1200 and €1600 (see Figure 2). This roughly corresponds to the figures obtained in a non-representative survey of 255 Polish care workers conducted in 2018 (Petermann et al. 2020).

Figure 2.

Monthly Net Income in Euros

In routinely examining what factors might explain the differences in wages, a simple bivariate linear regression revealed a statistically significant negative correlation between working hours and income. Respondents who worked longer hours tended to be paid less (see Figure 3).

Figure 3.

Correlation between Income and Working Hours

Since the income variable was not captured continuously, the same analysis was conducted using ordinal logistic regression with proportional odds. Here, similar results emerged: Working hours have a significantly negative correlation to income. The longer a respondent works, the smaller the logistical chance of achieving an income in a higher category. If we transform the cumulative logistic odds to the predicted probabilities of being in each of the categories, we can observe a continuous shift toward the lower income categories with increasing working hours (see Figure 4).

Figure 4.

Correlation between Income and Working Hours

To test the robustness of this correlation, a lasso regression including all observed covariates that could have a causal influence on income was used. Lasso is a regularized regression method that penalizes the absolute size of coefficients, shrinking less informative ones toward zero. The strength of this penalization is controlled by a tuning parameter, lambda (λ), which balances model fit and complexity: As λ increases, more coefficients are reduced or eliminated. This approach allows for the identification of variables that retain a stable association with the outcome even when many potential confounders are included.

At baseline (λ = 0 or no penalization) the coefficient of working hours is comparatively small. This does not say much, since most of the other covariates are coded as dummies, but it shows that other factors might contribute to the logistic chance of receiving a higher income. With increasing penalty, we show that as one covariate after another is eliminated from the model, the coefficient of working hours approaches zero much more slowly (see Figure 5).

Figure 5.

Correlation between Income and Other Factors

Comparing the highest λ-values, for which the covariate coefficients are not zero (with a granularity of .001), working hours become the second to last covariate to be eliminated from the model. The only covariate that is more persistent is language skills (see Figure 6). This implies that the negative correlation between working hours and income is quite robust and important for the model.

Figure 6.

Maximum Regularization Level (λ) before Each Variable Is Excluded from the Model

As this analysis is based on a non-representative sample, the results cannot be generalized for all Polish elder care workers in German households. Though possible biases of the sample might affect the average values, only an improbable combination of biases could impact the correlation between the variables. Thus, it can be concluded that longer working hours do not coincide with higher income among surveyed Polish elder care workers in Germany. On the contrary, a negative relation between the two variables is observed.

Using the survey data, we were not able to gain a better understanding of why this negative correlation occurs. We therefore draw on in-depth interviews with care workers and experts to shed light on wage negotiation dynamics within triadic relationships between mobile care workers, their clients and brokers, conditions shaping outcomes, and actors’ strategies. Analysis of in-depth interviews help to explain the core puzzle: Why do those who work longer hours earn less?

Transnational Care Work as Project Work

The dominant project-based care arrangements within brokered employment relations rely on circular employment (Neumann and Hunger 2016), in which periods of intense work in Germany lasting 6 to 8 weeks alternate with periods spent in Poland during which, as our interview participants stressed, carers recuperate, fulfill their own household and family-caring obligations, and take advantage of health services. The following interview excerpt [female, 68] exemplifies this model:

Researcher:

What model do you work in, how often do you go to Germany?

Respondent:

Two months out, two months in. From January onwards I will be in Germany for six weeks and then return to Poland for six weeks.

Researcher:

What is the reason for this model? Do you have to go home?

Respondent:

Because of my age, the number of years I’ve worked, I’m getting more and more mentally exhausted, so I think this model of six weeks for six weeks is the most beneficial for a carer.

A similar model has been identified for mobile care workers from Slovakia or Czechia working in Austria (Bahna and Sekulová 2019; Uhde 2026). Note that this way of working has not emerged solely because it suits care workers. It is also the result of regulations that care agencies in Poland must follow on the posting of workers and the coordination of social security systems (Matuszczyk 2021). Interviewed representatives of care agencies in Poland noted that they had adapted their business models to the needs of mobile care workers (e.g., by providing door-to-door transport services for workers). The head of a care agency that has been operating since the 1990s highlighted the changing nature of transnational home care, emphasizing that before 2011, care workers would usually leave Poland for several months at a time. Now, she pointed out, most agencies offer project-based roles taking care of specific clients, whose characteristics are communicated to the carer before departure. She added:

Nowadays most of my care workers are, on average, 60 years old so I can’t find anyone who would agree to be locked up with a client for six months. These ladies want to return to Poland, where they have their homes, families, and doctors. [Care agency 13, 2022]

This framing of work as a project or assignment suggests that care workers do not need time off for recuperation during the project phase since their recovery period can be postponed until they return to Poland. As a result, they are assumed to be able to work longer hours (de facto 24/7) while on assignment in Germany.

Further, the project model of employment promoted by brokers depends on the inclusion in a care worker’s contract of a list of defined tasks to be performed within a certain number of hours (e.g., six or eight). Tasks and work time may be spread over a 24-hour period depending on the needs of the care recipient. Agencies cite these flexible working hours to refute the idea that the live-in care model involves being on call 24 hours a day. They stress that the actual work time needed to perform contracted daily duties is dependent on the resourcefulness and ability of a given care worker. Representatives of care agencies we interviewed often mentioned this correlation: The more “skilful” and “professional” the carer, the fewer hours she needs to work. Such expectations on the part of brokers are reflected in narratives of care workers who often see themselves as being entirely in control of their work and leisure time. One spoke of being a “conductor of [my] own time” [female, 57].

Yet this shifting of responsibility for control over working time from employer (agency) to care worker entails difficulties. Care workers we interviewed struggled to decide whether particular activities, such as looking after a client at night, should be viewed as chargeable work. As one of our research participants put it, “[If] there is a knock or something, they get up, turn around, whatever—then I’m up. It is not that I don’t get to rest, or that I have to be on standby all the time” [female, 61]. The need to remain on call was cited by every research participant as the most common reason for wanting to renegotiate pay conditions. In such cases, care workers usually contact the agency in Poland and ask for higher pay.

Worker–Client Negotiations and the Conditions Influencing Outcomes

The worker–client dyad involves negotiations over both work and leisure time as well as additional payments from families for tasks not included in agency contracts. By contrast with the undocumented care model prevalent in many European countries (Bahna and Sekulová 2019), legal employment through a care agency in Poland guarantees mobile care workers obligatory time off. The frequency and duration of such breaks can be discussed and negotiated with care recipients or their families.

Interviewed care workers stressed that they get breaks during the day, often two hours after lunch but also at other times. Some mobile care workers admitted that while the families of their clients usually respect these conditions, it can be difficult to enforce them in practice when the carer concerned is unable to communicate their needs in German. Some experienced mobile care workers reported that they leave the house during such breaks to explore the surrounding area or go shopping. Family members of care recipients take over in their absence, though this requires agreement in advance.

Our results show that the amount of free time care workers have is closely linked to the health of the person they care for and the level of involvement of family and other formal carers. Care workers we interviewed reported that the health condition of the care recipient specified in the contract sometimes diverged from their true state of health, and that this might only emerge after care workers have arrived in Germany, as the following quotation illustrates:

I was lured [for this particular assignment] by [the prospect of] a separate flat. I thought it would be nice to have a lot of free time and not to live with the client, but it turned out different. First, I was supposed to take over from another carer, but the person got ill or had to leave for Poland suddenly, and so I had to stay for an additional shift. Also, the shifts were tiring, sometimes I did not have the strength to do any sightseeing, which I had planned to do. I was too tired to do it; it was one of my worse jobs. [female, 56]

While all research participants agree that older people with Alzheimer’s disease or different forms of dementia were particularly demanding in terms of care required, they noted that a person’s actual care needs might change over the course of a given care assignment. In turn, the level of remuneration agreed to at the beginning of a contract rarely reflected the actual health condition and needs of the client. Moreover, a striking feature of care services based on brokered employment relations is that care workers are often left without active support from the family of the person they are caring for:

The family of the person I care for is not here; I am alone with the elderly person. They are not interested in her condition. They give me money once a week to do the shopping and expect me to manage on my own. The daughter visits her mother at weekends, when I am off work. We see each other briefly. And that’s it in terms of our relationship. [female, 59]

Most interviewed mobile care workers are aware that in such cases they can call the agency’s office in Poland and try to renegotiate the terms of their assignment. But since agencies rarely provide additional remuneration to workers who provide care to severely impaired older people, it is common practice for care workers to negotiate additional payments directly with care recipients’ families. Moreover, some research participants reported being hired to provide care to one person only to discover that the person’s spouse required support as well. They would end up caring for both and negotiating extra remuneration, usually without informing their agency back in Poland.

Work contracts with agencies specify in detail the tasks to be performed by care workers (see next section for details). But as some research participants remarked, heavier household duties such as cleaning windows and staircases are generally not included and require negotiation with the care recipients’ families. Representatives of the care agencies we interviewed reported that they advise and warn their employees against taking on extra duties that German clients may want to entrust to them. In practice, care workers frequently receive extra pay “under the table” for such tasks, again without reporting this income to the employment agency in Poland or declaring it on their income tax statements. In this context, one interviewee with extensive experience working in Germany asserted that the capacity to communicate effectively with care receivers’ families and “insist” on additional remuneration for tasks lying beyond the scope of the contract was a pivotal skill. Additional undeclared income can therefore be earned outside of the carer’s regular contract, compensating for otherwise low wages for care work:

Most of the carers I know earn extra money this way. . . . The family usually asks us to wash the windows and clean the staircase, as well as sweeping the area outside the house. After so many years I know this isn’t my responsibility. . . . I do it because I prefer to have a good relationship with the family of my “granny,” but they have to pay me what a cleaner in Germany would normally charge for this, fifty euro, for example. [female, 63]

Care workers sometimes support care recipients’ families after the care recipient passes away. In such cases they clean the person’s home, sort their clothes and other belongings, or simply spend time with the family members, receiving additional money for this. These extra payments (care workers suggested that they might be in the range of €100–200) are viewed as compensation for earlier hard work for the family rather than reimbursement for time invested in these additional tasks. Importantly, agencies are not always informed about additional financial compensation arranged informally with care recipients’ families.

In summary, workers’ ability to negotiate work and leisure time depends on the health condition of care recipients and, given the formal premise that carers will postpone their rest until their return to Poland, the availability of family members to provide care and thus allow the care worker to take time off. The willingness of families to provide remuneration for additional household work determines whether care workers can earn additional income. The private household, the site in which work is performed, is a space lacking external controls and legal regulations. Care workers therefore need language proficiency and strong interpersonal skills to negotiate working hours and remuneration with clients.

Worker–Agency Negotiations and Conditions Influencing Outcomes

Research carried out with care agencies in Poland shows that these intermediaries combine elements of both the “wage-posting” and “wage-bargaining” systems in determining levels of remuneration. In each job listing, care agencies publicize the pay on offer for the care assignment at hand. As agency representatives we interviewed explained, this outcome reflects current approaches to rate-setting in the care sector, with an upper limit established based on the financial capacities of households requesting care services. This financial approach is further facilitated by weak enforcement of minimum wage regulations and the wage-setting rules laid down in the EU Posting of Workers Directive (see Kocher 2024). Interviews conducted prior to this change in legislation in 2021 suggested the dominance of a top-down wage-setting model consisting mainly of daily allowances (around €48 per day) and a Polish-level minimum wage (Marchetti et al. 2022). Importantly, published wage levels refer to monthly salaries since none of the sending companies use hourly rates.

While the salary level specified in care workers’ contracts is always agreed upon between the agencies and the families of care recipients, this does not stop workers attempting to seek higher wages (Sauer et al. 2021). The bargaining advantage enjoyed by mobile care workers is primarily the result of structural conditions underlying the model of transnational Poland-to-Germany care work, most prominently an acute shortage of labor in terms of both numbers and skills. Recruitment challenges as well as the high turnover and low retention of contract staff remain the most pressing challenge for all agencies interviewed, regardless of their size or business model. As a result, the concentration of intermediaries seeking candidates is increasing and competition for workers is becoming fiercer:

In reality, care worker[s] have dictated the terms for several years. However, here we are talking about women who speak German and can provide good references from previous employers. Unscrupulous companies compete fiercely for good staff and are willing to offer wages that are several dozen złoty higher. Many carers are leaving my company for another that is offering, for example, 100 złoty more. It’s hard to compete with this type of business practice—that’s the reality we face. [Care agency 17, 2023]

By contrast with intermediaries embedded in non-European mobility regimes (Xiang 2013; Jones 2021), actors operating in the EU internal market do not have at their disposal legal instruments they could use to bind a worker to them (see also Uhde 2026). Before the COVID-19 pandemic, it was common for care agencies to include so-called contractual penalties. These were high compensation payments to intermediaries for various types of misconduct or breach of contract (e.g., damage to items in care recipients’ homes or termination of employment before the agreed date). With the intensification of labor shortages, however, many interviewed care agencies are turning to more worker-friendly solutions that address the needs and well-being of employees. According to one care expert we interviewed, unusual measures such as the payment of higher net wages can be observed, although this is generally achieved through a reduction in social security contributions (Matuszczyk 2021). Other private intermediaries we interviewed reported similar practices employed by dishonest care agencies. They pointed out that although such entities may offer better net salaries, they actually deprive pre-retirement care workers of social security (Care agency 2, 2020; Care agency 7, 2021).

The above observation notwithstanding, care agency representatives we interviewed were of the opinion that care work is unique and that transnational care requires a different approach to remuneration given that workers also live in their workplace. One agency representative we interviewed argued that some activities should hardly be considered tasks requiring remuneration:

Is watching TV with a client during the day also work? And how should the employee be paid for this? It is up to employees to decide how much time they need for basic daily tasks. It would be absurd to pay for every minute, for every activity performed for the benefit of the care recipient. [Care agency 10, 2022]

The devaluation of housework and the difficulty in assessing the value of personal services is a constant element in discussions around remuneration for care (Folbre and Smith 2017). Furthermore, representatives of agencies in Poland admit that they seek to offer workers remuneration at the level of the Polish minimum wage, and that this is also the basis upon which social security contributions are calculated. Contrary to the dyadic model in home care, interviewed agencies defended the wages they offer on the basis that they need to take a commission to cover administrative and business costs.

Wage negotiations also depend on the quality of the workforce. Our research results indicate the importance for care workers to have language skills, and this narrative was often echoed in interviews with agencies:

[We set remuneration rates] according to language categories or German-language proficiency, which clients are also paying for when hiring carers. The lowest German-language proficiency level and easiest job is €1,200 net, I think—around €1,250. That’s the starting rate. The highest salary we currently offer is €1,750 or €1,800. This requires very good knowledge of German and involves a more challenging care assignment. [Care agency 5, 2020]

While lack of German is not an obstacle to employment, since such workers are simply directed to elderly people whose health conditions impair their communicative functions, a care industry expert we interviewed confirmed that care workers with very poor German earn less than those who have the skills to communicate fluently. Our survey data confirm that German language proficiency strongly determines the income of care workers (Hopfgartner et al. 2022). Noteworthily, several representatives of care brokering agencies we interviewed claim that they follow the preference of care recipient’s families when deciding whether to send them a care worker with poor, sufficient, or good language skills. Moreover, some agencies provide care workers with free German courses (usually online, either as podcasts or using textual materials). Paradoxically, as workers’ communication skills improve, they can expect higher pay, and may thus opt to work informally:

Ladies who have been working legally go to the black market. [So,] it goes the other way. Because when you look at it, provided that working illegally isn’t going to create problems for her, a lady who has been working for some years, [who] knows the language and the job perfectly, she’ll find a job. She just chooses her work. That’s better than in many agencies, right? She also [comes] recommended [so] everyone will take her with open arms. [Care agency 2, 2020]

Nevertheless, care workers with superior language skills are beneficial to agencies in terms of negotiating more profitable contracts with German clients; some agencies thus invest in language training for their employees [Care agency 11, 2022].

Moreover, practical knowledge gained on the job is rewarded with higher earnings. Workers can expect financial incentives to complete (non-mandatory) courses in first aid or other relevant skills. To enhance the professionalism of their services, numerous agencies operating in the transnational labor market have established training programs for workers who lack formal qualifications (for more details, see Palenga-Möllenbeck 2024). Yet there is no official system for recognizing formal and informal skills or for automatically translating acquired skills into higher earnings. Decisions about whether language and practical skills are acknowledged, rewarded, and translated into higher earnings remain in the hands of recruiters and project coordinators within individual agencies.

Representatives of agencies interviewed for our study stressed that they employ mostly unskilled workers to provide support to elderly people in German households. In justification of the low wages paid to Polish care workers they contrast this type of labor with the work of community nurses and qualified care personnel in institutional care settings in Germany. ⁴ As it turns out, this strategy is used to temper care workers’ expectations when it comes to wage increases. A lack of clearly defined criteria for live-in care workers’ salaries, irregular recognition of skills, the prevalence of non-monetary compensation, and the great variety of work contracts in this sector add up to opacity around earnings. This makes it difficult for care workers to formulate demands regarding wages or wage increases when interacting with sending agencies.

In this context, membership of open and closed groups on social media remains the only mechanism for acquiring knowledge about current wage levels in the home care market. As confirmed through interviews with several care workers, Facebook has become an easily accessible space for building both community and solidarity among workers, as well as for comparing working conditions and empowering those with less work experience. As a result, mobile care workers who are active online can build their capacity to negotiate with care companies when taking on contracts to care for clients. A care worker with several years of work experience in Germany explained the role of social media in helping carers navigate the transnational labor market:

Through care workers’ forums you get to know the agencies. Care worker[s] call one, two, three agencies to get information about the person in question, their illnesses, their income, and the region of Germany [they are in]. At that point I decide where I want to go, which agency I want to work with, and how long I want to work with them. [female, 65]

Our research confirms that workers’ bargaining power in respect to employment agencies is also constrained by their sociodemographic profile and life and retirement strategies (Matuszczyk 2021). Along with other studies (Bahna and Sekulová 2019; Horn et al. 2019; Uhde 2026), our survey shows that the typical in-home elder care worker is older than 50. Poland retains different retirement ages for men and women; the statutory retirement age for women is 60 but early retirement is available for women aged 55 or older who were born between 1946 and 1968 and worked in specific fields, including the public sector, health care, and social services. Employment rates among women aged 55–64 are below the EU average (54% compared to 60% in the EU and 71% in Germany) (OECD 2022). Thus, (early) female retirees are a deliberate target for agencies sending foreign care workers to Germany, especially because—as one expert we interviewed claimed—they may be unaware of their rights and therefore more likely to accept employment conditions dictated by agencies. Notably, dependency on agencies increases when care workers have no previous experience of working abroad.

Many care workers do not have specific plans regarding how long they intend to continue doing transnational care work through private agencies. For most, working for an agency offering a variety of packages and comprehensive support is either a stepping stone to better-paid employment or an alternative to unemployment in Poland. Care workers we interviewed admitted that either they themselves or people they know have accepted low wages for a limited period so they could, for example, pay for a large family celebration, cover unexpected expenses or, as one research participant told us, get “a cash injection” to repay a debt. Frequently, earnings from care work in Germany represent an additional income, and this extra income may be used for leisure, health care, travel, or home improvements. For some women, legal work in Germany through (fair, compliant) care agencies represents a way of getting a pension since care agencies make social security contributions in Poland (see Matuszczyk 2021).

Finally, accelerating demand for elder care in Germany, the decreasing supply of care workers in Poland, and increased competition between brokering agents entering the Polish market render non-wage benefits more important in the battle for “good workers” in the transnational care market. Representatives of care agencies stressed that workers posted to provide care services in Germany always have free accommodation and meals (the live-in model) and are not required to pay for transportation from their place of residence in Poland to their place of work in Germany. Additional incentives, such as one-off premium payments (e.g., at Christmas, Easter, or during the summer vacation), reward loyal care workers who stay with the same agency over a longer period. In respect to urgent care assignments, our research shows that employees may receive an extra bonus (e.g., €100) for a prompt return to work in Germany within a relatively short time frame. Carers can also earn extra money by recruiting other workers through leaflet distribution in Poland. Yet recruitment and the distribution of leaflets primarily serve as a mechanism for binding care workers to a given agency and fulfilling the legal requirement of regular employment in Poland, allowing carers to be posted for work abroad (Nowicka et al. 2021). Such irregular or minor payments make it more difficult for individual workers to make net wage calculations or otherwise compare their situation with that of other workers.

In summary, worker–agency negotiations take place in a regulated context (i.e., posting of workers regulations) in which the state sets some conditions, including a minimum wage or the format of contracts. However, care agencies exploit weaknesses in rule enforcement to set employment conditions. Nonetheless, market-based mechanisms give workers some leeway in negotiations. Specifically, outcomes are shaped by the financial capacity of clients (care recipients) and the availability of care workers. In this context, female mobile workers, especially those with poor language skills and without previous experience of mobile work, find themselves in a weak position when it comes to both structural discrimination in their country of origin and transparency in the terms of contracts.

Comparing Conditions Influencing Worker–Client and Worker–Agency Negotiations

Differently institutionalized contexts inform negotiations over work conditions between worker and client on one hand and worker and agency on the other. Worker–client negotiations take place in a private sphere which, as has been discussed extensively in the literature (Näre 2011), is characterized by lack of control and regulation. Such negotiations require carers to manage their emotions toward care recipients with whom they spend a lot of time, as well as demanding self-control in balancing work and leisure time. In turn, poor language and interpersonal skills may diminish workers’ bargaining power. Yet, unlike in (widely discussed) instances of irregular employment in the domestic sphere (Paul 2017; Cojocaru and Rosińska 2021), care workers brokered by an agency are less dependent on their clients (care recipients and their families) than irregular workers whose refusal to perform certain tasks may be sanctioned through reductions in salary or the termination of their contract.

By contrast, worker–agency negotiations are governed by state regulations and market principles. Outcomes are thus mediated by workers’ knowledge of employment conditions (often acquired from internet platforms and social networks or through personal experience) and personal skills in wage negotiation. In this context, it may not be workers’ professional skills that increase their bargaining power; rather, the increasing scarcity of workers may force the agencies to offer care workers better employment conditions.

In both contexts, workers’ language skills impact the outcomes of negotiations: In the domestic sphere, those with better German skills can more easily articulate their demands and negotiate leisure time or additional perks in exchange for additional work; by a similar token, agencies may be able to negotiate better pay and conditions for workers with better German.

Discussion and Conclusion

This article has sought to combine solid quantitative and qualitative data to explain how employment conditions are negotiated in transnational domestic work and what role private intermediaries play in such processes. Our study is one of the first to take an empirical approach to the issues of projectification of care work (Schneider 2024) and wage-settings between mobile workers and private labor market intermediaries (Weeraratne 2021). The main finding from our survey of Polish care workers in Germany has been that such workers seem to earn less money the more hours they work in German households. Seeking to explain this puzzle, we looked at data from in-depth interviews with mobile carers and private care brokers. This information led us to the discovery that workers negotiate their pay and working hours within two distinct contexts: in the domestic sphere with their German clients (care recipients and their families) and in interactions with care agencies in Poland. Bargaining conditions impact the outcomes of negotiations, and these two distinct institutional contexts require different bargaining skills from workers.

We contribute to the existing literature strand on private labor market intermediaries and on mobile workers and their ability to negotiate working conditions (Alberti and Sacchetto 2024). As we argue in this article, the working hours/wage disjunction is the outcome of two interlocked bargaining contexts that are characteristic of the triad client–worker–broker system. In this system, unlike in the dyadic systems that have been well described by previous research (Näre 2011), workers negotiate working hours and wages independently with different actors (Bidwell and Fernandez-Mateo 2008). Worker–broker negotiations center on the salary for a given number of working hours and tasks as regulated by a civil-law contract. Worker–client negotiations revolve around the actual hours worked for a given salary. Agreements between carers and their clients may include tasks not included in the contract between care worker and broker; such negotiations demand of care workers the practical, cognitive, and emotional skills required to navigate moral dilemmas and gendered and racialized power inequalities (Ambrosini 2015).

The originality of this study lies in its identification of the factors that influence workers’ bargaining power in brokered employment relations (Meardi 2012; Ewers et al. 2021). Mobile workers with better language and interpersonal skills are in a position to negotiate for both higher wages and shorter hours, which is in line with Ewers et al. (2021) findings. Notably, our research suggests that care workers’ earnings often improve over time as they improve their German-language proficiency and professional care skills. Our study enriches the discussion about the importance of structural conditions (i.e., demographic changes, EU mobile rights) as factors contributing to rising wages and the strengthening of the bargaining position of mobile care workers (Backes-Gellner and Tuor 2010; Zwysen 2024).

The triadic model of transnational care work differs significantly from dyadic models previously described in the literature, with consequences for care workers. First, this model is both made possible and shaped by EU regulations. In contrast to the pervasive global phenomenon of labor exploitation by intermediaries (Jones 2021), mobile workers within the EU care market enjoy greater autonomy and agency, thanks to the EU freedom of labor mobility (Shire et al. 2018; Szytniewski and van der Haar 2022). Unlike mobile workers in global labor markets, they do not fall into the intermediation trap described by Xiang (2013). If they are dissatisfied with the conditions offered by private intermediaries, EU mobile workers can easily resign and find work directly with a client or through a better intermediary (see also Meardi 2012).

Second, the triadic model offers certain securities that are unavailable to workers in a dyadic model and that relate to the disjunction between worker–client and worker–agency. The fact that workers hold their contract with an agency and not with clients gives them a degree of security in the event of a dispute with the client. This arrangement reduces their vulnerability in comparison to workers employed directly by their clients. Thus, although the disjunction between the two in terms of how work contracts are negotiated may lead to disparities between wages and working time, it should not be judged entirely negatively.

Despite the innovative nature of our findings, there are several limitations to our research approach. First, the results of our quantitative and qualitative research are not representative of the entire population of mobile carers in Germany or other European countries and therefore cannot be generalized. Second, as our sample consists of a specific research category—namely older women representing a particular generation—our results may not be comparable to other sectors in which young men dominate. Participants in our studies were significantly older than in similar studies (on average 10 years; compare with Bahna and Sekulová 2019). Our research is the first to shed light on the bargaining position of older mobile workers in the transnational care market. We believe age matters in regard to the capacity of such workers to improve their working conditions, but further comparative research is needed to establish how age influences workers’ outcomes (Dingemans et al. 2017).

Our findings may also be relevant beyond the elder care sector. In particular, sectors such as agriculture, construction, and platform work, which are characterized by a similar degree of informality and asymmetry in employer–employee relations, are becoming arenas in which private labor market intermediaries play an important role in employment relationships.