American employment is predominantly at will, meaning either side can end it at any time for any lawful reason with no notice. Most other developed countries require statutory notice scaling with length of service, often alongside redundancy pay and a requirement to justify the dismissal. The US exceptions are large-layoff notice under WARN, contractual terms, and union agreements.
The United States is the outlier
Most American employment is at will: either side can end it at any time, for any lawful reason, with no notice at all. No statutory notice period, no severance requirement, no need to show cause.
That is unusual internationally rather than normal. Most developed economies require notice scaled to length of service, and many require a stated reason and a process before a dismissal is lawful. Americans working for foreign employers, and foreign nationals working for American ones, routinely assume the arrangement they grew up with applies.
What the American floor actually is
The federal WARN Act requires 60 days’ notice, but only for large employers in mass layoffs, and only above specific thresholds. It is a collective notice statute rather than an individual one, and it says nothing about a single dismissal.
Some states go further — New York and New Jersey require 90 days in covered layoffs, and New Jersey mandates severance by years of service. That is the top of the American range, and it still applies only to qualifying group events.
The pattern almost everywhere else
Statutory notice that increases with tenure, commonly from a few weeks early on to several months for long service. Frequently a requirement to state a reason. Often a consultation process before a collective redundancy, and sometimes involvement of a works council or a labor authority.
Statutory severance is common too, calculated on service. The combined effect is that ending employment abroad is usually slower, more procedural and more expensive than in the United States, and cannot be shortened by agreement.
Garden leave, and why it is not a holiday
In several jurisdictions an employer can require you to serve your notice away from the workplace. You remain employed, remain paid, and remain bound by your duties — including exclusivity, which means you generally cannot start elsewhere until the period ends.
That is the point of it. Garden leave keeps a departing employee out of a competitor’s office for months while contractually unable to work, which is a stronger restraint than most non-competes and rarely described that way when it is offered.
The law follows where the work is performed
This is the rule that surprises people most. Notice, severance, termination protection and working time generally follow the country where you actually do the job, not where the company is incorporated or where the contract was signed.
A US employer cannot export at-will terms into a country with statutory notice by writing them into an agreement. Equally, an American working for a European employer from a desk in Ohio is generally an at-will employee, whatever the parent company’s culture suggests.
What this means if you are hired across a border
Establish which entity employs you, which country’s law governs, and what notice and severance apply. Those three answers determine your position far more than the salary does, and any employer running a proper arrangement will have them ready.
Be particularly careful with contractor arrangements. Where the relationship has the substance of employment, local authorities will treat it as employment regardless of the contract — which usually protects you, but only after a dispute nobody wants.
Why American severance exists at all
Given no legal requirement, it is worth understanding what the payment is for: a release of claims. Employers buy certainty, and that is the entire basis for negotiating it.
In jurisdictions with statutory severance the dynamic differs — a portion is owed regardless, and any negotiation happens on top of a floor. Knowing which situation you are in changes how the conversation should go.
The practical takeaway for an American reader
You almost certainly have no individual notice entitlement, and that is normal here and unusual elsewhere. Your protections come from the collective statutes, from your state, and from whatever your contract or employer policy provides.
Which makes the contract worth reading before signing rather than after. An agreed notice period is one of the few things you can negotiate into an American offer that most people never think to ask for.
This is general information rather than legal advice, and cross-border employment questions turn heavily on the specific jurisdiction.
Common questions
Does US law require notice of dismissal?
Generally no. Employment is predominantly at will, with WARN large-layoff notice, contracts and union agreements as the main exceptions.
How much notice do other countries require?
Statutory notice usually scaling with service, frequently one to three months and longer for senior or long-tenured staff, often with redundancy pay.
What is garden leave?
Remaining employed and paid through a notice period without attending work — common where statutory notice is long.
Which law applies if I work remotely abroad?
Generally the law where the work is performed. A US employer cannot import at-will terms into a country with statutory notice.
Is any US state different?
Montana, which requires good cause for dismissal after a probationary period.
Does US law require notice before dismissal?
Generally no. Most American employment is at will, with no statutory individual notice. WARN is a collective statute for large employers in mass layoffs.
Which country's law applies if I work remotely across a border?
Generally the country where the work is performed, not where the company is incorporated or the contract signed.
What is garden leave?
Serving notice away from the workplace while still employed and paid — and still bound by exclusivity, so you generally cannot start elsewhere until it ends.