This article aims at analysing the differences between European countries in the obstacles ex-offenders face due to having a criminal record. First, a comparative analytical framework is introduced that takes into account all the different elements that can lead to exclusion from the labour market by the dissemination of criminal record information. This model brings together social norms (macro level), social actors (meso level) and individual choices (micro level) in the same framework. Secondly, this model is used to compare the different impact of having a criminal record in Spain and the Netherlands. This comparison highlights three important findings: (1) the difference between norms of transparency/privacy and inclusive/exclusive ideals, (2) the significant role of social control agents, such as probation agencies and the ex-offenders' social network, in shaping the opportunities that they have, and (3) self-exclusion seems to be a key mechanism for understanding unsuccessful re-entry into the labour market.