European trade unions say the UK government’s claim that its controversial anti-strike bill is similar to laws on the continent is “bollocks”.

Business secretary Grant Shapps unveiled plans this week that could force people to work during strikes to maintain so-called “minimum service levels” in key industries.

The prime minister echoed Shapps and health secretary Steve Barclay on Wednesday when he sought to justify the bill by arguing that similar measures already exist in France, Italy and Spain.

But unions on the continent have flatly rejected the comparison and said the proposals would widen the gulf between the labour rights in the EU and the UK.

Livia Spera, general secretary of the European Transport Workers’ Federation, told openDemocracy that, for a country in Europe, “the UK already has restrictive rules on the right to strike. In most European countries, pay levels are determined through collective bargaining, and disputes are settled through negotiations.

“Limiting the right to strike and imposing minimum services have not successfully prevented conflicts. Quite the contrary – these limitations tend to extend them.”

Pablo Sánchez Centellas, a spokesperson for the European Federation of Public Service Unions, said: “It’s bollocks.”

The key difference, he added, is that in Europe “there is a lot of legislation to actually protect the right to strike while also having some sort of minimum service”.

There is no fundamental right to strike in the UK, unlike in most European countries including France, Germany, Spain and Italy, and unions have to go through more hurdles – in the form of ballot measures and notices – before a strike can take place.

“It is easier to organise Britain’s withdrawal from the European Union than it is to organise a strike in the UK because the thresholds are so high,” Centellas said.

In France, minimum service level legislation has been in place since 2008, but the levels are agreed through negotiations with trade unions. By comparison, the UK’s minimum service bill would allow the business secretary to decide statutory minimum service levels for NHS, fire, transport, education, border security and nuclear decommission, without negotiation with unions.

“The law required unions to give more advance notice of when they plan to strike so companies can organise minimum services. But in practice there is nothing that forces workers back to work,” said Cole Stangler, a French-American journalist who covers labour and politics.

The UK proposals would also allow employers to issue “work notices” requiring union members to continue working during strikes to meet minimum service levels. Anyone issued a work notice who strikes anyway will lose their legal protection from disciplinary action and could be sacked.

Shapps said that ministers would consult during the passage of the bill through Parliament what level of minimum service would be required for fire, ambulance, and rail services, adding: “For the other sectors covered in the bill, we hope to reach minimum service agreements so that we do not have to use the powers.”

European trade unions pointed out that such agreements should not be made in the middle of strikes.

“You do not come with this idea as hundreds of thousands of workers are striking or balloting – that is a provocation,” said Centellas. “This is not a reform of labour laws, it is an attack on unions.

“All the government is going to do is make people more angry. The NHS already has staffing issues; this will only lead to more resignations. You can’t try to stop the sea with your hands.”

Esther Lynch, general secretary of the European Trade Union Confederation, said in EU countries most disputes are settled through negotiation between trade unions and employers.

“There is no comparison to be made between that system of social dialogue and the political conflict the UK government is stoking over public sector pay,” she said in a statement on Thursday.

“If the UK government are really interested in learning from the best practice in Europe, they would sit down with trade union representatives to negotiate a fair deal as soon as possible, and they would not respond to strikes by bringing in more restrictive legislation.”