The ECDB does not systematically monitor changes in employment of registered SEs over the years (where employee figures are updated, the numbers for several years are indicated in the field). Moreover, the estimation of SE employment figures is very difficult with the data available to the ECDB, for several reasons. First, the SE Regulation does not require the publication of employment data. Also in national registries, this information is usually not available (let alone up-to-date). Second, most SEs have been set up by way of a subsidiary and therefore had no employees at the moment of founding. For many, this is likely to have changed in the meantime.

In addition, for the purpose of employee involvement, the concept of concerned subsidiaries and their employees is relevant. For example, an SE (serving as a holding or as the mother company of a group) may formally have no or very few employees. But in the context of the SE Directive the employees of concerned subsidiaries or establishments (which are to become a subsidiary or establishment of the SE upon its formation, but keep their original legal form) also have to be taken into consideration. This information, however, is usually available where access to an SE agreement on employee involvement exists. In many cases, it is not possible to clearly identify from the outside which subsidiaries 'belong' to an SE and should be counted in the calculation of the employees concerned by establishment of the SE. It is likely that a number of employee-free SEs have been registered by national registries without any negotiations on employee involvement, although there had been employees in one or more concerned subsidiaries. The situation is particularly problematic for Czech SEs where the large majority of SEs started as shelf companies with no employees and were afterwards sold. What happens in the company after activation usually remains unknown. It should once again be pointed out how problematic this is for safeguarding worker involvement rights.