US employers use software to punish workers at sixteen times the European rate. The gap is the law.

US firms use software to sanction poor performance in 67% of cases, while only 4% of surveyed European firms do so. Fifty-five percent of US companies monitor employee communications, compared with 6% in Europe. The OECD cites regulatory differences: Europe follows a centralized, rights-based framework; the US relies on a patchwork of agency and local rules. Common tools—SAP, Workday, Oracle, Jira, Asana, Trello, and time-tracking products—are not AI-based and fall outside AI-specific regulations.