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 of the developed world requires weeks or months of notice by statute. The United States requires none, and that single difference explains most cross-border confusion about how a job ends. It surprises people in both directions.
Most American employment is at will, meaning either side can end it at any time, for any lawful reason, with no notice at all. There is no statutory notice period, no severance requirement, and no obligation to show cause. Those three absences together are what at-will employment actually means in practice.
That arrangement is unusual internationally rather than normal. Most developed economies require notice scaled to length of service, and many require a stated reason and a documented process before a dismissal is lawful. Americans working for foreign employers, and foreign nationals working for American ones, routinely assume the system they grew up with travels with them.
What the American floor actually is
The federal WARN Act requires sixty days of notice, and only in narrow circumstances. It applies to employers with one hundred or more employees, and only above specific thresholds for the size of the layoff itself. It is a collective notice statute rather than an individual protection.
That means it says nothing at all about a single dismissal. Somebody let go on their own, at any size of employer, has no federal notice entitlement whatsoever. The statute was written for plant closings and mass layoffs, and it behaves accordingly.
Some states go further than the federal floor. New York and New Jersey require ninety days in covered layoffs, and New Jersey mandates severance calculated by years of service. That is the top of the American range and it still applies only to qualifying group events rather than to individuals.
The pattern almost everywhere else
The typical arrangement elsewhere is statutory notice that increases with tenure. It commonly runs from a few weeks early in employment to several months for long service. There is frequently a requirement to state a reason for the dismissal, and often a consultation process before any collective redundancy.
Some jurisdictions involve a works council or a labor authority in that process. Statutory severance is common as well, calculated on length of service rather than negotiated case by case. Those are entitlements rather than offers.
The combined effect is that ending employment abroad is usually slower, more procedural and considerably more expensive than in the United States. It also cannot be shortened by agreement, because the entitlement belongs to the employee rather than to the contract. An employer cannot buy its way out of a statutory notice period the way it can negotiate an American severance.
Garden leave, and why it is not a holiday
Several jurisdictions allow an employer to require you to serve your notice period away from the workplace. You remain employed throughout, you remain paid, and you remain bound by your duties to the employer. That includes exclusivity, which is the part that matters.
Exclusivity means you generally cannot start somewhere else until the period ends. Being paid to stay at home sounds like a benefit and functions as a restraint. The employer is buying your absence from a competitor’s office rather than giving you time off.
That is precisely the point of the arrangement. Garden leave keeps a departing employee out of the market for months while contractually unable to work, which is a stronger restriction than most non-compete clauses achieve. It is rarely described that way when it is offered, and it is worth reading in that light.
The law follows where the work is performed
This is the rule that surprises people most and it resolves most cross-border questions. Notice, severance, termination protection and working time generally follow the country where you actually do the job. They do not follow where the company is incorporated or where the contract was signed.
So a US employer cannot export at-will terms into a country with statutory notice simply by writing them into an agreement. The local statute applies to work performed locally, and a contractual clause saying otherwise is usually unenforceable in that country.
The reverse holds just as firmly. An American working for a European employer from a desk in Ohio is generally an at-will employee, whatever the parent company’s culture or handbook suggests. The employer’s nationality does not import protections you do not have.
What this means if you are hired across a border
Establish three things before signing anything. Which legal entity actually employs you, which country’s law governs the relationship, and what notice and severance apply under it. Those three answers determine your position far more than the salary figure does.
Any employer running a proper cross-border arrangement will have all three ready and will not find the question unusual. Hesitation on any of them is worth noticing. It frequently means the structure has not been thought through rather than that anything is being concealed.
Be particularly careful with contractor arrangements across borders. Where the relationship has the substance of employment, local authorities will generally treat it as employment regardless of what the contract says. That usually protects you, and only after a dispute nobody wants to have.
Why American severance exists at all
Given that no law requires it, it is worth understanding what the payment is actually for. Severance buys a release of claims, which means the employer is purchasing certainty rather than being generous. That is the entire basis on which it can be negotiated.
Understanding it that way changes the conversation completely. You are not asking for a favor and you are not appealing to fairness. You are discussing the price of something the employer wants, which is a different posture and a more productive one.
In jurisdictions with statutory severance the dynamic is different again. A portion is owed regardless of any agreement, and negotiation happens on top of that floor rather than from zero. Knowing which of the two situations you are in should shape how the conversation opens.
The practical takeaway for an American reader
You almost certainly have no individual notice entitlement at all. That is entirely normal in the United States and genuinely unusual elsewhere, and it is worth knowing rather than assuming otherwise. Nothing about long service creates one.
Your protections come from three places instead. The collective statutes where they apply, your own state’s rules, and whatever your contract or your employer’s written policy provides. The third of those is the only one you have any influence over.
Which makes the contract worth reading before signing rather than afterwards. An agreed notice period is one of the few genuinely valuable things you can negotiate into an American offer, and almost nobody thinks to ask for it. 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.