The termination notice periods vary across different countries, including the minimum legal requirements and the duration of the statutory notice period. In this post, we have listed 14 countries with their varying notice requirements:
1. Austria
Employers need to follow contractual notice terms if agreed notice terms do not exist. The minimum notice period to terminate an employee without cause varies based on one’s length of service from six weeks up to five months after 25 years of service. Blue-collar employees must be given at least two weeks’ notice prior to termination. Employment law does not make reference to payment in lieu of notice, but if employer does not adhere to the notice requirements, an employee is still entitled to the remuneration they would have received during the appropriate notice period.
2. Belgium
An employment contract can be terminated by mutual consent between the employee and the employer at any time. The minimum notice period to terminate an employee varies depending on the employee’s length of service and ranges from 2 to 64 weeks. Similarly, the notice period of employee resignations varies from 1 to 13 weeks depending on the employee’s length of service.
3. Brazil
In Brazil, employers may terminate an employee’s employment with or without just cause. Dismissal for just cause does not require advanced notice, however an employee may dispute this form of termination in the labor courts. Termination without just cause requires an employer to provide employees with 30 days’ notice if the employee is paid less frequently than weekly or if they have worked for the employer for one year of longer. Three or more days are added to this period for each additional year of service up to 90 days.
4. Canada
According to the Canada Labor Code, employers need to provide a minimum of two weeks of notice or pay in lieu of notice to employees who have worked for more than three months unless the employer has just cause to terminate the contract. The employer must provide severance pay to employees with one or more year of employment.
5. France
Under the French law, a termination notice must specify the cause of dismissal and include certain mandatory information. An employer may also terminate an employment contract at will if there is just cause. Dismissal without cause can result in damages awarded to the employee of up to two years’ salary.
The notice period when terminating depends on the seniority of an employee:
- One month notice for employees with six months to two years of seniority, or
- Two months’ notice for employees with more than two years of seniority
Employees with seniority below six months, the notice period will be decided by the collective agreement or the company’s common practice. French law also establishes a strict process for the formal termination of employees and deviation from this process may make the employer liable for damages to the employee.
6. Germany
Similar to France, in Germany, employers are limited in their ability to terminate employees and must follow strict guidelines to terminate employees. In general, all employees are protected by The Protection Against Unfair Dismissal Act and may only terminate an employee if they meet one of three statutorily defined reasons for termination: personal, conduct-related, or business-related grounds. The minimum notice period to terminate an employee increases depending on the employee’s length of service and ranges from 2 weeks during the six-month probationary period, four weeks’ after the probationary period has concluded, and up to 7 months’ notice after 20 years of service.
7. Israel
Israel’s Advance Notice of Dismissal and Resignation Law makes it mandatory both for employees and employers to provide notice to the respective parties regarding their intent to end employment. The length of the notice period is based on the tenure of employment and the frequency that the employee is paid. The notice period to be provided increases from one day to up to one month depending on the length of service.
8. Luxembourg
The length of the notice period is based on the tenure of employment. Notice periods are usually calculated as:
- Two months’ notice for less than five years of service
- Four months’ notice for service between five and 10 years
- Six months’ notice for more than 10 years of service
Employees terminated for gross misconduct are not given a notice period if an employer has fewer than 150 employees.
9. Netherlands
Employers in the Netherlands can terminate an employment contract in various ways, which are:
- Termination by mutual agreement
- Expiration and non-renewal of a fixed-term contract, where the employer must give one month notice to the employee
- Termination of the employment contract by court ruling
- Termination of the employment agreement during the probationary period
- Termination due to an urgent reason
10. Portugal
At-will employment does not exist in Portugal. Employers may only dismiss employees for “just cause”, or conduct that makes the continuation of the employment relationship impossible. In order to terminate an employee, the employer must present an employee with a statement of intention to dismiss the employee and furnish evidence of misconduct to justify the termination. Employers who look to terminate an indefinite contract must provide an employee with 15-75 days of notice depending on the employee’s length of service. For fixed term contracts, employers must provide an employee with 30 days of notice if the contract is for a term greater than 6 months, and 15 days’ notice if the contract term is less than 6 months.
11. Saudi Arabia
In the case of an indefinite employment contract, both parties may terminate the employment for a valid reason specified in a written notice that is to be provided to the other party 60 days prior to the intended termination date.
12. Switzerland
Employers have to provide notice periods of one, two or three months to employees based on their service length. Both parties can also agree on longer or shorter notice periods in writing. However, if the notice requirements are not specified in the employment contract or collective labor agreement, the written notice period ranges from seven days to three months, depending on the length of service. Agreeing parties may not agree on a notice period that is less than 30 days.
13. United Arab Emirates
Employers in the UAE may terminate an employment contract for a valid reason for at any time as long as they provide the employee with 30 days’ written notice. Shorter notice periods may apply to workers who are paid daily or those who have worked for less than five years. In the Abu Dhabi Global Market (ADGM) the notice period varies based on the length of service. For those who have worked less than three months, the notice period is seven days. For those who have worked at least three months, but less than five years, the notice period is 30 days. For those who have worked for five or more years, the notice period is 90 days.
14. United Kingdom
Employers in the UK are required to provide a minimum statutory notice period of one week to employees if they have been working for more than a month, but less than two years. After completing two years, employees receive one weeks’ notice for each year of service, up to a maximum of 12 weeks’ notice after 12 years of service.
15. USA
In the United States, employers practice at-will employment in which they are not required to provide employees with any notice period prior to the termination of their employment. In spite of this, it is customary for both parties to provide the other party with two weeks’ notice under most circumstances.
If you need detailed information regarding country-specific minimum notice requirements or other issues related to your global workforce, please email us at info@mihi.com or call us at +1 408-703-0455. Watch a video on how Mihi works. Check out our sister company Global Upside.
