UK vs US: Who comes out on top for employee rights?

Author: Rocio Carracedo Lopez

On both sides of the Atlantic, global employers are bracing themselves for the wide-ranging changes to key employee rights that are on the horizon.

With the publication of the Employment Rights Bill in October 2024, employers in the UK are looking at changes to unfair dismissal, flexible working, statutory sick pay, bereavement leave and paternity leave, among other proposals.

In the US, Donald Trump is heading back to the White House in January 2025 and it is anticipated that his return will have a significant impact on employers.

How different are current employment laws in the US and UK? 

In this article, we explore how the countries currently compare for some key employee rights.

How can global HR teams manage employment rights in different countries?

Employers hoping to expand into another country must have a thorough understanding of the employment rights to which employees are entitled wherever they employ people, and they need to keep on top of legal changes. Although there are some similarities between the US and UK, there are also some stark differences.

Further, considering legal minimums is not enough; employers must take into account cultural norms and local employee expectations if they are to attract and retain the people with the skills they need.

Global guide for employers: Employee rights can help global HR teams to understand minimum employment rights across the globe, and how to manage situations in which multiple different rights exist for employees in the same organisation.

In light of the upcoming changes in both countries, the greatest challenge global employers will face is keeping up to date with evolving laws on employee rights to ensure compliance, mitigate risks and maintain good working relationships across borders. HR & Compliance Center UK and US provide the most comprehensive collection of HR resources on the market to help HR to stay on top of upcoming reforms.