The UK's 2025 Employment Rights Act is a big step forward, but other countries already offer far more. From France's right to disconnect to Brazil's 13th month salary, here are ten workplace rights we're still missing.
By Lisa Branker, Head of Employment Law at employment law solicitors, Beecham Peacock
Over the course of the year β and continuing into 2027 β the 2025 Employment Rights Act is coming into effect in the UK. 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. But while the UK is making strides, it's still falling short compared to other nations. And the U.S. is even further behind in many areas.
You might assume that the U.S. leads the world in labor protections, but that's far from the truth. In fact, there are several workplace rights that other countries already enjoy β and we don't. Here are ten examples that might surprise you.
### France: The Right to Disconnect
France passed a law in 2017 giving employees the legal right to 'disconnect' from work communications outside working hours. Companies with 50 or more employees must negotiate specific hours during which staff can be contacted electronically. They're not alone: Australia, Ireland, Belgium, Spain, and Portugal also have similar protections.
Australia's version, effective August 2024, even bars employers from punishing workers who don't answer calls or emails after hours. In the U.S., there's no such federal right β only the 40-hour workweek under the Fair Labor Standards Act, which doesn't address after-hours communication at all.
### Brazil: The 13th Month Salary
Brazil's dΓ©cimo terceiro salΓ‘rio 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 installments.
This is considered a legal wage, not a discretionary bonus, and is owed pro-rata even on dismissal. It's meant to boost the economy and help with end-of-year expenses. Similar policies are mandatory across most of Latin America and parts of Europe (Greece, Italy, Portugal, Spain). The U.S. has nothing comparable β bonuses are entirely at the employer's discretion.
### 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 U.S. law, but it's becoming a hot topic in many state legislatures. Some companies have voluntarily adopted similar policies, but it's far from the norm.
### France: Mandatory Commute Reimbursement
No U.S. employer is legally required to subsidize commuting β but French employers must reimburse at least 50% of the cost of employees' public transport season tickets for the home-to-work commute. This covers all staff, including part-timers and trainees.
With the average American commute now over 27 minutes each way, this would be a welcome benefit for many workers. But it's not on the horizon anytime soon.
### 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. Companies with over 25 employees must notify candidates within 45 days of their interview, informing them whether they've been successful.
Employers who fail to respond could face fines of up to CA$100,000 (around $73,000 USD). The U.S. has no comparable law β candidates are often left wondering about their status for weeks or months.
### Germany: Board-Level Employee Representation
According to German law (Mitbestimmungsgesetz), large companies with over 2,000 employees must give workers half of the seats on their supervisory board. Companies with 500β2,000 employees must reserve one-third of the available seats.
This ensures that employees have a representative voice in all top-level business discussions. The U.S. has nothing comparable β corporate boards are typically filled with executives and investors, not workers.
### Netherlands: The Right to Request Reduced Hours
In the Netherlands, the Dutch Flexible Working Act allows employees at firms with more than 10 staff to request fewer hours, a different working pattern, or a change in work location. Employers must seriously consider these requests and can only refuse for valid business reasons.
This flexibility is a game-changer for work-life balance. In the U.S., requesting reduced hours often comes with the risk of being passed over for promotions or even losing your job.
### The Takeaway
These examples show that the U.S. has a long way to go when it comes to workplace rights. While some of these policies might seem radical, they're already working in other countries. The question is: when will we catch up?