Mass layoff and collective redundancy notices compared

United States: the WARN Act

The Worker Adjustment and Retraining Notification Act was enacted on 4 August 1988 as Pub. L. 100-379 and took effect 6 months later ¹. It covers employers with 100 or more employees, excluding part-time employees, or 100 or more employees who together work at least 4,000 hours a week ¹.

A plant closing is a shutdown that causes employment loss for 50 or more employees at a single site in any 30-day period ¹. A mass layoff covers at least 33 percent of employees at the site and at least 50 employees, or at least 500 employees, excluding part-time staff ¹.

Under 29 U.S.C. 2102, the employer must not order the closing or layoff until 60 days after it serves written notice ². Notice goes to each representative of affected employees or each affected employee, to the state rapid response body and to the chief elected official of the local government ². Shorter notice is allowed for a faltering company seeking capital and for business circumstances that were not reasonably foreseeable ².

European Union: Directive 98/59/EC

Council Directive 98/59/EC of 20 July 1998 sets minimum rules on collective redundancies ³. Member States choose one of two definitions ³.

The EU waiting period

Projected collective redundancies notified to the competent public authority take effect not earlier than 30 days after the notice ³. Member States may let the authority cut that period ³. The authority uses the period to seek solutions ³. Where the initial period is shorter than 60 days, Member States may let the authority extend it to 60 days ³.

Great Britain: the HR1 notice

Section 193 of the Trade Union and Labour Relations (Consolidation) Act 1992 sets the duty to notify the Secretary of State ⁴. An employer proposing to dismiss 20 or more employees as redundant at one establishment within 90 days or less must notify in writing at least 30 days before the first dismissal takes effect ⁴. For 100 or more employees, the period is at least 45 days ⁴. The notice must come before the employer gives notice to end any of the contracts ⁴.

Where there are representatives to consult under section 188, the notice must name them and the date consultation began ⁴. The employer must give each representative a copy ⁴. The legislation.gov.uk text of section 193 shows amendments by the Employment Rights Act 2025, in force from 6 January 2026 for specified purposes only, that add a test based on a threshold number in section 195A ⁴. Readers should check the commencement notes on that page for which version applies on a given date ⁴.

Canada: federal group termination

Section 212 of the Canada Labour Code covers employers that end the employment of 50 or more employees within one industrial establishment, at the same time or within four weeks ⁵. They must give written notice to the Head at least 16 weeks before the first termination ⁵. A copy goes at once to the Minister of Employment and Social Development, the Canada Employment Insurance Commission and any union representing a redundant employee ⁵. Employees without a union receive a copy, or the notice is posted in a conspicuous place ⁵.

Side by side