Employment rights: an international perspective

So while UK employment lawyers need to keep their primary focus on their home jurisdiction, it is still worth stepping back and considering how other countries regulate employment rights.

So how does the UK shape up? And will its global position change as a result of our Government’s current legislative programme?

Those dealing with cross-border issues will be aware that, in general, the UK labour market is more lightly regulated than most of its European neighbours, but its workers enjoy stronger protection than their counterparts in the US.

Research published by the TUC last year, adopting metrics developed by the University of Cambridge, suggests that labour laws in the UK, taken as a whole, are about half as protective as those found in France and significantly below other leading European countries such as Spain, Italy and Germany. It considers this gap is too wide to be bridged by the reforms currently planned by the Labour Government.

But while the regulatory landscape may differ, recent research also indicates that employers across the major economies of the world have many concerns in common. These include how to engage with the increasing use of AI, respond to escalating geopolitical tensions, and deal with increased worker stress and anxiety. And, it seems, all worry about increased labour market regulation, regardless of their relative starting point.

In this context employers in the UK are probably not in such a bad position, despite the challenges on the horizon. These, of course, include responding to the extensive changes set out in the Employment Rights Bill, about which I wrote recently here.