By Lisa Branker, Head of Employment Law at employment law solicitors, Beecham Peacock
Over the course of the year – and continuing into 2027 – the 2025 Employment Rights Act is coming into effect. Beginning in April of this year with the removal of the earnings threshold for statutory sick pay, the new Act represents the most significant overhaul of UK workplace law for decades.
The changes brought about by the Act will increase workers’ rights across the country, boosting job security and expanding family rights.
Though we might see the UK as a leading nation when it comes to labour laws, you might be surprised to hear that we’re still lagging behind in a number of other areas. So, here are ten examples of workplace rights held by other countries.
France: Right to Disconnect
France legislated that employees had the legal right to ‘disconnect’ from work communications outside working hours in 2017. This means that companies with 50 or more employees are forced to negotiate specific hours during which staff can be contacted electronically. They’re not alone: Australia, Ireland, Belgium, Spain and Portugal also give their workers the right to disconnect.
Australia’s version, effective August 2024, also bars employers from punishing workers who don’t answer calls or emails out of hours. The UK has no such right – only the 48-hour average working week, under the Working Time Regulations.
Brazil: Statutory 13th Month Salary
Brazil’s décimo terceiro salário has been a constitutional right since the 1960s. This law obliges employers to pay every formal employee an extra month’s wage each year, split across two mandatory instalments.
Intended to boost the economy, assist with end-of-year expenses and ensure that employees are comfortable over the holiday periods, this is considered a legal wage, rather than a discretionary bonus, and is owed pro-rata even on dismissal.
Other countries offer similar policies. It is mandatory across most of Latin America and parts of Europe (Greece, Italy, Portugal, Spain); the UK has nothing comparable.
Spain: Paid Menstrual Leave
In 2023, Spain became the first European country to introduce menstrual leave, giving paid time off to workers experiencing periods that are medically certified as incapacitating. This paid time off is funded by the state from the first day of absence.
No such provision exists in UK law, but this continues to be a hot topic in parliament.
France: Mandatory Commute Reimbursement
No UK employer is legally required to subsidise commuting – so France are putting us to shame here too. French employers must reimburse at least 50% of the cost of employees’ public transport season tickets for the home-to-work commute, covering all staff including part-timers and trainees.
Canada: No Interview ‘Ghosting’
In Ontario, Canada, recent law provisions have made it illegal for employers to ‘ghost’ candidates who have applied for a role with them. Companies with over 25 employees must notify candidates within 45 days of their interview, informing them whether they have been successful.
Employers who fail to respond could face fines of up to CA$100,000 (around £50,000). The UK has no comparable law.
Germany: Board-level Employee Representation
According to German law (Mitbestimmungsgesetz), large companies with over 2,000 employees are required to give workers half of the seats on their supervisory board. Meanwhile, companies with 500–2,000 employees must reserve one-third of the available seats.
This ensures that members of the workforce have a representative voice in all top-level business discussions. The UK, meanwhile, has nothing comparable as yet.
Netherlands: Right to Request Reduced Hours (with high flexibility!)
In the Netherlands, the Dutch Flexible Working Act allows employees at firms with more than 10 staff to request fewer hours, a different working schedule or location – and the employer must grant the request unless there is a compelling business interest to deny it.
While a similar law exists in the UK under the right to request flexible working, it’s much easier for employers to deny – under one of eight broad categories. Meanwhile, in the Netherlands, the request is automatically considered granted if the employer takes too long to respond!
So, while the UK continues to implement new changes to our employment law infrastructure, there are still a number of areas that are overlooked.
