This article outlines a concept for analysing practices of European works councils. Much previous research has focused its attention merely on a single institution or actor, for instance the European works council, transnational agreements or trade union federations. However, previous research in the field suggests that transnational labour relations often involve many actors on different levels inside and outside an MNC who interact, refer to different cultural patterns and draw power to act from various sources. To cover those processes, a structuration theory framework is developed that models different ‘action fields’, which actors refer to in their social practices of cross‐border employee representation. The framework is illustrated with case studies of Toyota and General Motors. The benefits and limitations of the new perspective are discussed with reference to previous accounts.