International Employment Law Alert – July 2026

England

Updated Employment Rights Act timeline. In July, the UK government set out the latest timetable for measures introduced, or expected to be introduced through 2026 and into 2027. This has since been amended to make clear it was published under the Starmer government. But we anticipate most of the reforms will come into effect as planned. We provide an updated roadmap of these upcoming changes here.

You can also read our Employment Law Alerts that cover the recent cases and developments in the UK that employers need to know about.

Belgium

New employment legislation affecting working time and notice periods. From 1 June 2026, two new acts together introduced a wide range of changes to Belgian labour law, including the following:

• Internal working-time rules: shifting from listing all fixed working schedules to a framework-based approach in the work regulations;
• Minimum weekly working time for part-time employees: reduction from one-third to one-tenth of a full-time working schedule;
• A new cap on the maximum notice period for new employment contracts of 52 weeks;
• The abolition of the prohibition on night work, permitting work between 8 pm and 6 am, subject to compliance with the applicable company-level procedures;
• Voluntary overtime: the framework for voluntary overtime is further expanded, allowing employees to perform additional hours on a voluntary basis with simplified formalities. This increases flexibility for both parties, although it remains subject to limits and specific formal requirements (e.g. written consent).

Changes to the automatic wage indexation mechanism. From 1 June 2026, the “cent index” means that wage indexation is no longer fully applied on a percentage basis to the entire salary of the employee, but is capped above a certain threshold (€4,000). As a result, part of the index increase is not passed on to the employee, but is effectively reduced, with a portion being redirected to the government. Employers will need to verify with their Belgian payroll provider whether they are aware of this change and will apply it at the next indexation. Non-compliance with the “cent index” is treated as a breach of mandatory wage rules, potentially exposing the employer to social criminal fines and payroll corrections.

Implementation of the EU Pay Transparency Directive delayed. Negotiations appear to have come to a standstill between the social partners within the National Labour Council. In principle, an opinion from the National Labour Council must be issued, after which the legislative work can be continued. In any event, Belgium did not meet the 7 June 2026 deadline and has recently requested a six- month extension for the implementation of the Directive. It has also submitted a list of around 30 questions to the European Commission in order to clarify several aspects of the Directive. It is expected that the EU Directive will have an impact on several pay transparency related obligations under current Belgian law.

In parallel, the Federal Ministry of Employment is developing an online platform (Project BE-MAGIC) that will provide tools and analytical methods, enabling employers to easily implement and use gender-neutral job evaluation and classification systems.

Trial periods. As highlighted previously in our April alert, a new law re-introducing a “trial period” will enter into force on 1 August 2026, applying to all employment contracts commencing on or after that date. During the first six months of employment, both employers and employees may terminate the employment relationship by giving just one week's notice, regardless of which party initiates the termination. This shortened notice period applies automatically and does not need to be expressly included in the employment contract. Importantly, only the notice period is affected. All other employment law obligations remain fully applicable, including the statutory notification formalities, anti-discrimination rules and special dismissal protections. Employers should review their template employment contracts and HR policies to ensure that any references to the previous notice period regime are updated accordingly.

Please contact our team in Belgium for further details.

France

New supplementary birth leave. A new "supplementary birth leave" (congé supplémentaire de naissance) has been available since 1 July 2026, following the publication of implementing decrees on 31 May 2026. Each parent may take up to two months of additional paid leave (70% of net salary for the first month, 60% for the second), on top of existing maternity, paternity and adoption leave. The leave may be split into two one-month periods and must start within nine months of the birth or, for adoption, the child's arrival in the household. Employees must give at least one month's written notice. The leave covers all children born or adopted from 1 January 2026 onwards.

EU Pay Transparency Directive - transposition update. France missed the 7 June 2026 deadline to transpose the EU Pay Transparency Directive. An updated draft law was circulated to social partners on 5 June 2026 and is expected to be tabled in Parliament in the next few months, with progressive entry into force between late 2026 and 1 January 2028. Notable features include mandatory salary range disclosure in job advertisements, a new set of pay gap indicators (replacing the current gender equality index) for companies with 50+ employees, and a strengthened burden of proof allowing employees to rely on statistical evidence where no direct comparator exists.

Cap on sick leave prescriptions. A new decree caps the duration of sick leave prescriptions from 1 September 2026. Initial prescriptions may not exceed 31 days and extensions are limited to 62 days per renewal. These limits apply to all prescriptions by doctors, midwives and dentists. Healthcare professionals may exceed them where the patient's condition requires it, provided they document the medical justification. Until now, no statutory cap existed.

Please contact our team in France for further detail.

Germany

Coalition announces key employment law reform proposals. On 1 July 2026, the coalition committee agreed on a number of employment law reform proposals. The most significant measures include:

• Fixed-term employment contracts without objective justification should be permitted for up to four years, with a maximum of six extensions.
• Termination of high-earning employees with an annual gross salary of approximately €180,000 or more should be facilitated in return for the payment of a severance amount (see more information here).
• Sick notes via telephone consultation should be abolished.
• Employees should be required to submit a certificate of incapacity for work from the first day of absence.

Working Time Act reform further delayed. The anticipated draft bill reforming the German Working Time Act was not included in the government's major reform package announced in July 2026. Instead, the coalition parties have agreed to revisit the topic after the summer break. In June 2026, however, an unofficial draft bill prepared by the Federal Ministry of Labour and Social Affairs has been circulating. While the Ministry has emphasised that the proposal remains subject to further revision, the current draft falls short of the government's stated objective of providing greater flexibility for employers. In particular, a shift from the current daily maximum working time to a weekly maximum working time framework would only be permitted under a collective bargaining agreement. The draft also confirms that employers will remain responsible for recording employees' daily working hours, including the start, end, and duration of work, with non-compliance potentially resulting in administrative fines. In addition, trust-based working time arrangements (Vertrauensarbeitszeit) would continue to be subject to comprehensive time-recording requirements. You can read more about it here.

Introduction of partial incapacity for work from 2027. From 2027, employees covered by statutory health insurance will no longer be classified solely as either fully fit for work or unfit for work but will also be recognised as partially unfit for work. Depending on a doctor’s assessment, they will still be able to perform 25, 50 or 75 per cent of their normal workload whilst on sick leave. The aim is to reduce sickness-related absences and make return-to-work processes more flexible. You can read more about it here.

EU Pay Transparency Directive implementation delayed. As of 7 June 2026, no German implementing legislation had been enacted. Germany has therefore failed to meet the implementation deadline. According to the competent Federal Ministry, the implementing legislation should in principle come into force in early 2027; however key requirements such as reporting obligations for companies and the individual right to access information should be scheduled to take effect for the first time in June 2028. For employers, simply carrying on as before is legally risky. Even without an implementing law, the Directive already has indirect implications for the design and justification of remuneration systems. Moreover, it has been reported that the German Government has been lobbying at EU level to seek a relaxation of certain obligations. You can read more about it here.

Please contact our team in Germany for further detail.

Hong Kong

Updated policy on visa renewal. The Immigration Department has clarified that visa holders must leave Hong Kong if their visa expires, even where an extension application is being processed. To compensate, the filing window for extension applications under major employment and talent schemes has been extended from four weeks to three months.

Junior employees’ fiduciary duties. In Eventmaster Ltd v Chen Hiu Kwan & Ors, the Court of First Instance confirmed that fiduciary duties may extend beyond directors and senior employees to salespersons. This may be the case where the employer is considered vulnerable because it lacks control over how the salesperson uses information acquired in the role and depends on the salesperson to pass on that information.

Statutory minimum wage rate increases. Effective from 1 May 2026, the statutory minimum wage has increased from HK$42.1 to HK$43.1 per hour. The monthly monetary cap on the requirement for employers to record the total number of hours worked by employees has also been raised from HK$17,200 to HK$17,600 per month in tandem.

Please contact our team in Hong Kong for further detail.

Ireland

EU Pay Transparency Directive implementation delayed – phased implementation expected. The Directive was required to be implemented into Irish law by 7 June 2026. As Ireland has missed the transposition deadline, phased implementation is ultimately expected. The Irish Government had previously published the General Scheme of the Equality (Miscellaneous Provisions) Bill 2024 on 15 January 2025 which was Ireland’s first step towards implementation of the Directive. Further detail on this Bill is available here. Based on the relevant governmental department’s statements to date, it appears that pre-employment pay transparency obligations may be prioritised for early transposition. The government has also indicated that employers will not be penalised for not having all elements of the Directive implemented by the June 2026 deadline, which has now passed.

In March 2026, the European Commission, in consultation with the European Institute for Gender Equality (EIGE), updated EU-wide guidelines on gender-neutral job evaluation and classification. A national toolkit based on these guidelines and tailored to assist Irish employers in meeting their obligations under the Directive, will apparently also be published in due course.

Changes to contractual retirement. On 29 June 2026, the Employment (Contractual Retirement Ages) Act 2025 (the Act) and the updated Code of Practice on Longer Working 2026 (the Code) came into effect. The Act establishes a new statutory right for employees nearing their contractual retirement age, if below the state pension age of 66, to oppose their contractual retirement. Pursuant to the Act, employees may submit written notice of their refusal to consent to their contractual retirement, which must be submitted no more than 12 months and no later than three months in advance of the contractual retirement date.

Once a valid notification is made to the employer, the contractual retirement age can only be enforced if the employer can objectively and reasonably justify doing so.

Upon receipt of a valid notification, employers are obliged to provide a reasoned reply within one month; if seeking to enforce the retirement age, their reply must include objective justification for doing so by reference to a legitimate aim. The legitimate aim must be related to the retirement of the specific employee and the means of achieving this aim must be both appropriate and necessary. Failure to provide a reasoned response within the prescribed time limit is an offence and can result in a Class A fine of €5,000. Additionally, such a failure would give the affected employee a right of action pursuant to the Act. Such a claim would be brought before the Workplace Relations Commission and the maximum award for a successful claim is 104 weeks’ remuneration.

The Code provides guidance to employees and employers on the new legislation, including as to the consideration of requests to work beyond the contractual retirement age.

The Code also sets out procedures for employees aged 66 and over to make requests to continue working. Such requests should be processed in line with the guidance under the Code. Any disputes arising from such requests will continue to be dealt with under the existing age discrimination framework as set out in the Employment Equality Acts.

High Court decision highlights importance of fair procedures. In the recent High Court decision of Central Bank of Ireland v CD, the Court refused to confirm a prohibition notice against a senior executive of an Irish fund management company under the fitness and probity regime, finding that the process was undermined by significant breaches of natural and constitutional justice and a lack of basic procedural fairness.

The Court noted that a serious allegation had been made against the senior executive and the consequences of such allegations, if upheld, would be detrimental in terms of his credibility and good name and thereby potentially catastrophic for his ability to continue to work in the financial services area. Where credibility, honesty and truthfulness are in issue from the start of a process, the alleged wrongdoer is entitled to the full range of constitutional rights, including to be given a fair opportunity to understand the allegations against them, review the relevant evidence, respond meaningfully and have their position properly considered before any conclusions are reached. The Court found that the Central Bank had failed to afford the senior executive such rights, including through its failure to interview him or relevant witnesses identified by him, the absence of an oral hearing, and its very belated attempts to address deficiencies only at a late stage of the process.

Although the case arose in a regulatory rather than employment context, the judgment contains important lessons for employers. The principles of natural justice and fair procedures are deeply rooted in the Irish Constitution and are equally relevant to workplace investigations and disciplinary processes. Where allegations may affect an employee's reputation or career prospects, employers should ensure that employees are given the benefit of the above entitlements.

This decision serves as a reminder that shortcomings in an investigation process may ultimately undermine subsequent findings and expose decision-makers to legal challenges. See here for more detail on this interesting decision.

Please contact our team in Ireland for further detail.

Italy

EU Pay Transparency Directive implementation. Legislative Decree No. 96/2026, implementing the EU Pay Transparency Directive, entered into force on 7 June 2026. It provides for new requirements on recruitment and pay transparency, including the disclosure of starting pay or pay ranges in job advertisements, a prohibition on salary history enquiries and enhanced employee information rights. Employers with at least 100 employees will also be subject to phased gender pay gap reporting requirements and, in certain circumstances, joint pay assessments with trade union representatives. Employers should now prioritise a comprehensive mapping exercise of job descriptions, employee classifications and current remuneration practices to ensure compliance.

1 May Decree: Fair remuneration – minimum wage. On 30 April 2026, the Italian Government issued a new Decree (converted with amendments by Law No. 112/2026), in force since 1 May 2026, addressing (inter alia) one of the most debated issues in the Italian and European labour law landscape, i.e. the definition of fair and adequate remuneration. The measure follows in the footsteps of the EU Directive on adequate minimum wages in the European Union and expressly references, among its underlying principles, articles of the Italian Constitution, as well as the EU Directive on pay transparency. The Decree provides measures for employers to comply with fair wages, providing that they ensure that the individual economic treatment paid to each employee is not lower than the overall compensation package established by the NCBA and entered into by the most comparative, representative trade unions at a national level for the relevant sector, activity, company size and legal nature of the employer. Non-compliance with the fair wage requirement may result in exclusion from public incentives and benefits provided under the Law.

New duration limits for staff leasing workers. Law No. 122/2026 establishes a new "double track" for temporary assignments, offering much greater flexibility. For workers hired on a permanent basis by an employment agency, assignments to the same user company can last up to an additional 36 months (even if not consecutive) on top of the usual 24 months, for a total of up to 60 months (unless the client’s national collective agreement provides for a different limit). The new 36-month limit now applies, starting from 28 June 2026, and any assignment periods worked by the employee prior to this date do not count towards the new limit.

Please contact our team in Italy for further detail.

Netherlands

Restricting restrictive covenants. A legislative proposal that is set to restrict the use of restrictive covenants by employers (de Wet modernisering concurrentiebeding) has been sent to the Advisory Department of the Council of State. If adopted, this act will significantly restrict employers in their current use of restrictive covenants. The limitations would affect non-compete, relationship- and anti-poaching clauses (so not solely non-competes). For these clauses, employers would become obligated to limit the temporal scope to a maximum of 12 months and to explicitly agree on a geographical scope (both in writing). Also, such clauses would only be valid if they are timely invoked by the employer. Subsequently, invoking the restrictive clause would obligate the employer to compensate the employee: this compensation would be at least half of the monthly salary for each month of restriction (or more if agreed). The government aims to present the proposal to the House of Representatives in the final months of 2026. Thus far, no comments have been made on a possible date for entry into effect.

Pseudo self-employment. On 16 June 2026, the Assessment of Employment Relationships and Legal Presumption (Clarification) Act (VBAR) was adopted by the Senate. VBAR introduces a legal presumption of employment for self-employed workers who earn up to €38 gross per hour. Going forward, this amount will, be subject to indexation. It will be up to the self-employed worker to invoke the legal presumption, after which the employer will have to demonstrate why the self-employed worker is not employed under an employment agreement. If this cannot be sufficiently demonstrated, the worker will be deemed employed. The official date of entry into effect of VBAR will be announced by Royal Decree.

In addition, the government is also working on a legislative proposal for the Self-Employed Persons Act. The aim of this act is to provide clarity on when a worker is, in fact, a self-employed worker or not. This new proposal is intended to replace an earlier legislative proposal that aimed to clarify when a worker is employed under an employment agreement. This last proposal has not yet been submitted to the House of Representatives.

The Flexible Workers (Increased Security) Act has been adopted. On 7 July 2026, the legislative proposal for the ‘Flexible Workers (Increased Security) Act was adopted by the Senate. Among other things, the Act contains an amendment of the provisions on succession of fixed-term employment contracts (ketenregeling). One of the changes is to cancel the current arrangement regarding the (max) six month interval between fixed term employment agreements and to replace this arrangement with an administrative expiry period of three years. Other measures included in the Act are the abolishment of on-call contracts. Instead the government introduces so-called bandwidth contracts in which the maximum working time may not be larger than a 130% of the minimum working time. Lastly, the Act contains measures to enhance the position of posted workers. Among those measures, is a stipulation that the total of the posted worker’s terms of employment must be, at least, equal, to that of regular employees directly employed by the hirer. For most of the obligations of the Act entry into force is scheduled to take place on 1 January 2028. For the obligation related to the remuneration of posted workers, this is scheduled to enter into force on 31 December 2026.

Register here for our Autumn webinar where we will provide practical insights into the developments that matter most to employers in the Netherlands.

Please contact our team in the Netherlands for further detail.

People's Republic of China

Enhanced procedural requirements for unilateral termination in Beijing. From 1 May 2026, Beijing implemented new Measures for the Implementation of the Trade Union Law, mandating that employers must notify their internal trade union of the reasons for unilateral termination at least five working days in advance. Employers without an internal union must notify the higher-level trade union. Even if the substantive grounds for termination are lawful, failing to complete this five-day pre-notification step may still result in the termination being deemed illegal by labour arbitration tribunals and courts.

Please contact our team in the People's Republic of China for further detail.

Singapore

Employment Claims Tribunal (ECT) decision on wrongful dismissal. In JGP v JGQ [2026] SGECT 1, Singapore’s first published ECT decision, an employee succeeded in a claim for wrongful dismissal even though she had breached her employer’s claims reimbursement policy. The employer had failed to prove the dishonest and intentional element of misconduct it alleged; there was a “lesser” wrong of negligent misconduct, but in the tribunal’s view, this did not justify dismissal. The decision underscores the need to conduct a due inquiry for misconduct-related dismissals, and the importance of stating an accurate reason for dismissal, if one is to be provided at all. Further insight on this case is available here.

Retirement and re-employment ages increased from 1 July 2026. From 1 July 2026, Singapore’s statutory retirement age increased from 63 to 64, and the re-employment age from 68 to 69. This is part of a phased plan to raise the retirement and re-employment age to 65 and 70 by 2030. Under the Retirement and Re-employment Act 1993, employers must offer to re-employ eligible employees up to the prevailing re-employment age or, if no suitable roles are available, provide an employment assistance payment.

Please contact our team in Singapore for further detail.

Spain

Second draft of Pay Transparency Directive implementation proposal published. Spain has released a second draft proposal for the implementation of the EU Pay Transparency Directive. The proposal would introduce significant new transparency obligations for Spanish employers in line with the Directive, including an individual right for employees to request pay information, enhanced requirements regarding pay-setting criteria and pay progression, mandatory gender pay gap reporting for employers with 50 or more employees, and strengthened pay audit obligations. The draft also contemplates mandatory corrective measures where unjustified pay differences are identified and would prohibit contractual clauses restricting employees from disclosing salary information. Although the text remains subject to change during the legislative process, employers should continue assessing the potential impact on their remuneration structures and internal pay transparency processes.

Protection against age-related barriers. A recent Spanish Supreme Court judgment has reinforced the possibility of challenging age-based distinctions included in collective redundancy agreements. The Court confirmed that an employee may pursue a discrimination claim focused specifically on the economic treatment resulting from an age threshold contained in a collective redundancy scheme, even where the dismissal itself is not challenged. The judgment highlights that collectively negotiated redundancy arrangements remain subject to equality and non-discrimination principles and may be challenged where age-based differences cannot be objectively justified. Employers should therefore carefully assess the rationale underpinning age-related criteria used in severance and early-retirement schemes.

Limits on unilateral reductions of remote working arrangements. The Spanish Supreme Court has clarified the limits on employers' ability to unilaterally modify remote working arrangements. According to the Court, changes affecting essential terms of an individual remote working agreement, including the percentage of remote work, generally require the employee's individual consent and cannot be imposed unilaterally by the employer. The judgment reinforces the contractual nature of remote working arrangements and highlights the need for employers to carefully assess any planned reductions in remote working entitlements, particularly where existing individual agreements are in place.

A softer approach towards dismissals linked to permanent incapacity. Recent Spanish doctrine suggests a more nuanced approach to dismissals linked to permanent incapacity. Courts are increasingly focused on whether employers have properly assessed reasonable accommodation measures before proceeding with termination, while recent case law is clarifying that the required adjustments must remain proportionate and reasonable. This trend reflects a gradual shift away from automatic termination approaches and towards a more detailed assessment of reasonable adjustments and alternative solutions before ending the employment relationship. Employers should therefore carefully review accommodation options and thoroughly document the steps taken before proceeding with dismissals linked to permanent incapacity.

Please contact our team in Spain for further detail.

UAE / ADGM

UAE - Updates to the Civil Code. Federal Decree-Law No. 25 of 2025 (the New Civil Code), which applies in the UAE (excluding the DIFC and ADGM) and came into force on 1 June 2026, is expected to play an increasingly important role in employment disputes. The new legislation introduces express obligations to negotiate in good faith during pre-contractual discussions and to disclose information that is material to the other party's consent. While these changes are not expected to fundamentally alter existing employment practices, they may increase scrutiny of recruitment processes, contractual negotiations and settlement arrangements. UAE employers should review offer letters, settlement agreements and related templates to ensure key information is clearly communicated and appropriately documented. Particular care should be taken when conducting recruitment and settlement discussions, with an increased focus on maintaining clear records, adopting consistent processes and ensuring employees have a reasonable opportunity to consider important employment decisions.

UAE - Wage Protection System (WPS) and late payments of wages. From June 2026, salaries in the UAE private sector are due on the first day of each month under a revised WPS framework. The WPS framework does not apply to employers in the DIFC or ADGM. The new rules introduce earlier monitoring and enforcement measures for delayed salary payments and form part of the UAE's continued efforts to improve compliance with employee wage obligations and enhance labour market transparency. Although the DIFC and ADGM do not operate under the WPS, employers in those jurisdictions should also remain mindful of their obligations regarding the timely payment of salary and termination entitlements. In the ADGM, wages must generally be paid within 14 calendar days of the relevant pay period, and employers may be subject to fines of up to USD 5,000 for non-compliance. While the DIFC does not impose an equivalent financial penalty for late salary payments during employment, employers are nonetheless expected to pay employees on time. In addition, employers should be aware of the time limits for settling termination entitlements. Termination entitlements must generally be paid within 21 days following termination in the ADGM and within 14 days following termination in the DIFC. Employers across all UAE jurisdictions should review payroll processes and payment approval timelines to ensure wages and termination entitlements are paid on time and to minimise the risk of regulatory action, penalties or employment claims arising from delayed payments.

UAE – Emiratisation targets remain under scrutiny. The deadline for private sector employers to achieve the first-half 2026 Emiratisation targets expired on 30 June 2026 (DIFC, ADGM and free zone employers are generally excluded from Emiratisation targets). From 1 July 2026, financial contributions apply to employers that failed to meet the required increase in Emirati representation in skilled roles, with penalties of AED 10,000 per month for each Emirati hire shortfall. Employers should continue to review recruitment and workforce planning strategies to ensure compliance with ongoing Emiratisation requirements.

ADGM - Growing interest in pension and savings schemes as an alternative to gratuity. We are seeing increased interest from ADGM employers in pension and savings schemes as an alternative to traditional end-of-service gratuity arrangements. These structures can provide greater flexibility and help align benefits across international workforces. Employers should ensure any transition away from gratuity is carefully implemented and documented, as failures in implementation may expose employers to claims for statutory gratuity in addition to any pension or savings benefits provided.

Please contact our team in the Middle East for further detail.