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Global HR News

International HR updates digest: January 2026

As an international employer, it is essential to stay up-to-date with all the regulatory changes that impact your people. Our specialists have compiled useful information on recent and upcoming changes to HR compliance from around the world.

In this months edition the UK’s labour law reform makes progress, Poland takes a step closer to implementing the EU Pay Transparency Directive, Spain strengthens its parental leave rights, and Japan upgrades its occupational health requirements.

Americas


Canada (Alberta)

Extended job‑protected leave for long‑term illness and injury

Effective 1 January 2026, Alberta increased the maximum duration of job-protected leave for long‑term illness and injury under the Employment Standards Code. The leave entitlement will rise from 16 weeks to 27 weeks per calendar year, following an amendment to the Employment Standards Regulation. This change brings Alberta in line with federal standards as well as the regimes in British Columbia, Manitoba, Nova Scotia, and Ontario.

Eligibility and employer obligations

Employees qualify for the leave once they have completed 90 days of employment.

The leave is unpaid, unless an employment contract or collective agreement provides for paid benefits. Employers must continue to provide the employee with the same or an equivalent position upon return to work. The employee’s service is considered continuous during the leave period for the purpose of calculating years of service and related entitlements.

Employers are reminded that requests for medical leave frequently intersect with their duty to accommodate employees under the Alberta Human Rights Act. This applies both when an employee goes on leave and when they return to work.

Employers are encouraged to:

  • review and update workplace policies, handbooks, and disability management procedures to reflect the extended 27‑week leave entitlement
  • ensure HR teams understand the overlapping human rights obligations, particularly regarding accommodation
  • assess internal processes for managing medical documentation, return‑to‑work planning, and job protection requirements.
Brazil

Proposed legislation would create a new paternity leave framework

Brazil’s Chamber of Deputies has approved Bill No. 3,935/2008, a proposal that would significantly reform the country’s paternity leave system and establish a permanent legislative framework. The text is now before the Federal Senate for review, where it may still be amended.

Key features of the proposed law

  • Extended paternity leave
    The bill proposes a gradual increase in paternity leave from the current five days to 20 days, rising in stages over the first four years after the law takes effect. Employees would continue to receive full pay, but the financial responsibility would shift from employers to the Social Security system. Employers would initially pay the benefit, then offset this amount against their social security contributions.
  • Additional leave in special circumstances
    The proposal includes extra protections in more complex family situations:
    • If the mother or newborn is hospitalised, the leave would be extended for the duration of the hospital stay, and the normal leave period would begin only once they are discharged.
    • Where the child has a disability, the leave period would increase by one‑third.
    • In the event of the mother’s death, the surviving parent or another guardian assuming parental responsibility would receive the full leave entitlement and related benefits.
  • Job protection and flexibility
    The draft law would prohibit dismissal without cause during the leave period and for one month afterward. Employees could also choose to take annual leave immediately after paternity leave, provided they give 30 days’ notice.

Impact on employers

If enacted, the bill would require companies to update internal policies, adjust payroll procedures for reimbursement mechanisms, and prepare employees for changes to leave entitlements. The legislation remains under discussion, and employers should monitor its progress through the Senate.

Asia Pacific

Australia (Victoria)

New restrictions on NDAs in workplace sexual harassment cases

Victoria has become the first Australian jurisdiction to legislate restrictions on the use of non‑disclosure agreements (NDAs) in workplace sexual harassment matters. The Restricting Non‑Disclosure Agreements (Sexual Harassment at Work) Bill 2025 has now passed Parliament, following recommendations from the Australian Human Rights Commission to curb the misuse of NDAs in such cases.

The law applies to sexual harassment matters involving complainants who usually work or are based in Victoria. It does not affect NDAs entered into before the legislation commences. Its overarching purpose is to protect the health, safety and welfare of workers by regulating confidentiality clauses in sexual harassment settlements and addressing power imbalances between complainants and employers.

Key preconditions for entering an NDA

Under the Bill, a workplace NDA relating to a sexual harassment complaint may only be entered into if the following conditions are met:

  • Voluntary request: The complainant must clearly request and expressly wish to enter into an NDA.
  • Mandatory information statement: The employer must provide the complainant with a workplace non‑disclosure agreement information statement outlining rights, obligations, and how the NDA regime operates.
  • Cooling‑off period: The complainant must be given a 21‑day review period before signing (which they may waive or request to shorten).
  • No pressure: Employers and individual respondents must not pressure or coerce the complainant to enter an NDA.
  • Acknowledgment form: The complainant must sign a document confirming all preconditions have been met.
  • Failure to comply with these requirements may render the NDA unenforceable.

Limits on confidentiality terms

The Bill prohibits NDAs from restricting a complainant’s ability to share Material Information with certain trusted or professional parties, including:

  • Lawyers
  • Medical practitioners
  • Police
  • Confidential friends or family members
  • Ministers of religion

Material Information includes the respondent’s identity and details of the alleged or substantiated conduct. Employment contracts must also comply and cannot contain terms that improperly restrict such disclosures.

However, complainants are restricted from sharing Protected Information, which includes:

  • The respondent’s identity where the respondent is under 18
  • The amount of compensation received, except when disclosing to Centrelink, a financial adviser, or a tax agent

NDAs between employers and respondents

Where an NDA is entered into between the employer and the alleged respondent, the agreement cannot:

  • Prevent the employer from disclosing substantiated sexual harassment findings to a prospective employer; or
  • Restrict an internal or external workplace investigation.
Japan

Significant amendments to labour and occupational health and safety laws in 2026

Japan is preparing to implement a broad set of amendments to labour and occupational health and safety regulations by the end of 2026, reflecting a heightened focus on workplace safety and employee wellbeing.

These changes, supported by forthcoming Ministry of Health, Labour and Welfare (MHLW) guidelines, will introduce new compliance obligations for employers in areas such as customer harassment prevention, work–life balance, sexual harassment safeguards, gender pay gap reporting, and safety protections for diverse worker groups. Below is an overview of the key developments.

Amendments to the Comprehensive Promotion of Labor Policies Act

  • Customer harassment prevention
    From 1 October 2026 (provisional), employers must introduce measures to prevent customer harassment, defined as behaviour by customers, business partners, or other third parties that exceeds socially acceptable norms and negatively impacts the work environment.
    Expected measures include:
    • policies addressing customer harassment
    • a designated reporting/support contact for affected employees
    • additional safeguards in line with upcoming MHLW guidelines.
  • Support for employees balancing work and medical treatment
    Effective 1 April 2026, employers will be required to make reasonable efforts to accommodate employees managing medical treatment while continuing to work. Measures should align with MHLW guidance and aim to foster a supportive environment for workers with ongoing health conditions.

Strengthened sexual harassment protections for job seekers

Employers will also be obliged to take measures to prevent sexual harassment against job applicants, including students, interns, and candidates participating in interviews, OB/OG visits, internships, and similar activities.

Mandatory actions will include:

  • Establishing internal policies
  • Training all personnel involved in recruitment
  • Ensuring safeguards across every stage of the hiring process

Noncompliance may result in administrative guidance or public disclosure. The implementation date will be set within 18 months of the amended act’s promulgation.

Gender pay gap and female management ratio disclosure

From 1 April 2026, employers with 101 or more employees must publicly disclose their gender pay gap and the percentage of women in management roles.

Disclosure of measures to prevent sexual harassment of job seekers will also become a prerequisite for obtaining special certification. Employers should begin preparing now for these enhanced transparency requirements.

Amendments to the Industrial Safety and Health Act

  • Safety and health measures for sole proprietors.
    Phased implementation from 1 April 2026 will extend occupational safety and health obligations to sole proprietors working alongside employees. This includes:
    • applying health and safety measures to contractors and sole proprietors
    • reporting occupational accidents involving sole proprietors
    • requiring site operators to coordinate safety across all personnel, including those not directly employed.
  • Expansion of mandatory stress checks
    All employers, including those with fewer than 50 employees, previously exempt will be required to conduct statutory stress checks.
    The effective date will be set within three years of the amended act’s promulgation. Employers may need to engage external service providers to implement these requirements.
  • Preventing occupational accidents among senior workers
    From 1 April 2026, employers must take steps to promote workplace safety for senior workers. Expected measures include improvements to the physical work environment, adjustments to job duties, and training or other forms of support to ensure safe working conditions.

These upcoming amendments will require employers in Japan to review their internal policies, reporting systems, and health and safety frameworks. Preparing in advance and closely following forthcoming MHLW guidance, will be critical to ensuring compliance and maintaining safe, fair, and transparent working environments.

    European Union

    Austria

    More protection for freelance employees

    Effective 1 January 2026 Austria has implemented significant reforms affecting freie Dienstnehmerinnen (freelance employees), closing long‑standing gaps in their legal protection.

    The new legislation marks a major shift by aligning key aspects of freelance work more closely with traditional employment relationships.

    Statutory termination rules introduced

    Until now, termination rules for freelance employees were largely unregulated. The new law amends the Austrian Civil Code to provide:

    • clear notice periods for open‑ended freelance contracts
    • defined termination rights for both parties
    • greater legal certainty around ending freelance engagements.

    This brings freelance workers closer to the protections enjoyed by standard employees.

    Access to Collective Bargaining Agreements (CBAs)

    A major innovation is the creation of a legal basis allowing freelance employees to be covered by collective bargaining agreements, or be included in existing CBAs.

    This change aims to improve working conditions, pay standards, and overall bargaining power for freelancers, groups previously excluded from Austria’s collective labour framework.

    Closing loopholes and preventing misuse

    The reform responds to concerns that freelance arrangements were sometimes used to circumvent employment protections. By introducing minimum standards and clearer rules, the government aims to reduce the incentive for employers to rely on freelance contracts as a substitute for employment, ensure fairer treatment and more predictable working conditions, and also strengthen social protection for a growing segment of the workforce.

    Alignment with broader labour law reforms

    The changes form part of a wider legislative package amending the Austrian Civil Code and the Labour Constitution Act. From 2026 onward, freelance workers will be placed on a more equal footing with employees in both termination rights and collective representation.

    What this means for employers

    Organisations engaging freelance employees in Austria should:

    • review existing freelance contracts to ensure compliance with new termination rules
    • assess whether CBAs may now apply to their freelance workforce
    • reconsider workforce models where freelance arrangements were used primarily for flexibility or cost reasons
    • prepare for increased scrutiny of freelance classifications.
    Belgium

    Labour market reforms effective 1 January 2026

    On 9 December 2025, the Belgian federal government approved a package of labour market and employment law reforms that will apply from 1 January 2026. Below is an overview of the key changes and practical actions for employers.

    1. Meal vouchers
      The maximum value of a meal voucher will rise from EUR 8 to EUR 10.
      Employers may contribute up to EUR 8.91, while employees must contribute a minimum of EUR 1.09. The tax‑deductible amount per voucher for employers doubles to EUR 4.00, provided the employer contribution is set at the maximum level. For employees, the enhanced contribution could amount to a benefit of approximately EUR 880 per year.
      Although the increase is optional, employers may wish to enhance their benefits offering. Organisations choosing to raise the voucher value will need to review and update their collective labour agreement or issue contractual addenda to reflect the change.
    2. Flexi work – expanded availability and higher earnings threshold
      A major reform is the move from an opt‑in to an opt‑out model. Flexi work will now be permitted across all sectors, unless restricted by an industry‑level collective labour agreement.
      Additional changes include:
      An increase to the annual tax‑free flexi‑job earnings ceiling, rising from EUR 12,000 to EUR 18,000, with yearly indexation.
      This measure applies retroactively for the 2025 income year.
      Employers may find flexi jobs a cost‑effective addition to their workforce planning. However, companies should monitor whether their sector intends to introduce any limitations.
      Action: Evaluate the use of flexi work as a flexible staffing tool and prepare a compliant flexi‑job contract template.
    3. Student employment – updated templates and a larger hours quota
      From 2026, the annual quota for student employment will increase to 650 hours, and the minimum working age will be lowered to 15, subject to specific conditions.
      Fifteen‑year‑old students must be enrolled in full‑time education and are subject to strict working time rules, including:
      During school periods
      • max two hours on a school day
      • max eight hours on a non‑school day
      • max 12 hours per week.
      During school‑free periods of at least one week
      • max eight hours per day
      • max 40 hours per week.
      Further restrictions include:
      • only ‘light work’ (to be defined by Royal Decree)
      • no overtime, night work, Sundays, or public holidays
      • an additional rest day (Saturday or Monday) in addition to Sunday rest
      • breaks of 30 minutes for days over 4.5 hours and one hour for days over six hours
      • at least 14 hours between shifts.
    4. Abolition of the career start obligation
      From 1 January 2026, employers with more than 50 FTEs will no longer be required to hire a minimum number of young workers. This removes a compliance obligation for larger organisations.

    New sick leave and reintegration rules effective 1 January 2026

    Belgium has introduced a series of significant reforms aimed at reducing long‑term sickness absence and encouraging earlier reintegration into the workforce. The new measures, in force since 1 January 2026, place additional responsibilities on both employers and employees and require updates to workplace policies and internal procedures. Long‑term absenteeism has become a major social and economic challenge in Belgium, prompting the government to implement targeted changes designed to support medically feasible returns to work and strengthen employer involvement in absence management.

    Key changes employers need to know

    1. Stricter rules for employee medical certificates
      Employees may continue to take limited sick leave without providing a medical certificate, but the annual exemption has been reduced from three days to two (non‑consecutive days).
      If the exemption is referenced in the company’s work regulations, these must now be updated.
      Small employers (fewer than 50 employees) may opt out of the exemption entirely by expressly stating this in their work regulations. In those cases, a medical certificate is always required.
    2. New employer obligations for absence management
      From 1 January 2026, all employers must establish a formal procedure for maintaining contact with employees on sick leave, which must be added to the company’s work regulations as part of a broader absence policy.
      Updating the work regulations requires following Belgium’s mandatory consultation processes. Given the late publication of the reforms, authorities are expected to show some tolerance around initial compliance timing, but employers should begin updates without delay.
    3. Faster access to termination for medical force majeure
      Employers may terminate an employment contract for medical force majeure when an employee is permanently unable to return to work, subject to strict procedural requirements.
      The earliest point at which this procedure can now begin has been shortened from nine months of uninterrupted sick leave to six months. This allows employers to take action sooner where a long‑term, irreversible incapacity is evident.
    4. Updated rules for reintegration and new sanctions
      Reintegration rules have been tightened:
      After eight weeks of sick leave, the employer must obtain an assessment of the employee’s work capacity from the occupational doctor. If the doctor concludes that reintegration is possible, a formal reintegration procedure must begin within six months of the start of the sick leave. Failure to initiate the process can result in fines of EUR 200 to EUR 4,000 per affected employee.
      These measures reinforce proactive management of long‑term absences.
    5. Expanded rules on relapse and guaranteed salary
      Belgian employers generally pay a guaranteed salary for the first 30 days of sick leave. Previously, a relapse within 14 days of returning to work did not restart the guaranteed salary requirement.
      This relapse window has now been significantly extended:
      • if the relapse occurs within eight weeks, no guaranteed salary is owed (subject to some exceptions)
      • if the relapse occurs after eight weeks, the guaranteed salary rules apply again.
    6. New rules for partial work resumption
      Employees may return to work on a reduced schedule while still formally on sick leave.
      Previously, if the employee became sick again during the first 20 weeks of partial work resumption, no guaranteed salary was required.
      As of 1 January 2026, the 20‑week limit is abolished. No guaranteed salary is due at any time during the period of partial work resumption if the employee becomes unable to work.
      This change is intended to encourage gradual returns without imposing additional financial risks on employers.

    What employers should do now

    Employers operating in Belgium should take the following steps:

    • Update work regulations to reflect the new rules on medical certificates, absence‑management procedures, and reintegration processes.
    • Review absence management and HR workflows to ensure timely assessments and reintegration actions.
    • Train HR and line managers on the shortened timelines and new contact obligations.
    • Review payroll practices in light of the revised relapse and partial work resumption rules.
    • Monitor employees on long‑term sick leave to ensure compliance with the updated force majeure and reintegration procedures.

    Federal learning account: abolished

    After multiple delays and widespread criticism, Belgium has officially scrapped the Federal Learning Account (FLA). From 1 January 2026, employers no longer need to use a federal platform to record employee training activities. While training obligations remain fully in place, the removal of the FLA significantly reduces administrative pressure on HR teams.

    What has changed?

    At the end of 2025, the Belgian legislator formally repealed the FLA framework. The decision reflects long‑standing concerns about excessive administrative complexity, an overlap with existing training requirements, and limited practical value for employers.

    The FLA was intended as a mandatory digital tool to track individual training rights and completed training. However, repeated implementation delays and operational challenges ultimately led to its abandonment.

    Importantly, the repeal applies retroactively to 1 January 2025, meaning employers were never required to submit FLA data for 2025.

    Any training information already uploaded to the FLA will remain accessible until 31 December 2026. After that date, all data will be permanently deleted.

    The abolition of the FLA does not remove employers’ training duties. Requirements relating to individual training rights, training plans, and internal record‑keeping remain.

    France

    New obligations to support employment and career development for senior workers

    A law dated 24 October 2025 introduces several measures aimed at strengthening the employment and career management of senior workers.

    Mandatory career interviews

    Employers must now conduct two dedicated career discussions for senior employees:

    Mid‑career interview (around age 45): Designed to review the employee’s career path, assess the suitability of their current role, and identify opportunities for skills development or mobility.

    Pre‑retirement interview (within two years before age 60): Focused on planning the final stage of employment, including adjustments to working conditions and access to training or transition schemes.

    Measures to support continued employment

    The law promotes longer and more sustainable careers for older workers through tools such as flexible working arrangements, progressive retirement options, and targeted training to maintain employability.

    Introduction of the “Contrat de Valorisation de l’Expérience” (CVE)

    The legislation also creates the CVE, an indefinite‑term employment contract available on an experimental basis for five years. It is open to:

    • workers aged 60+, or
    • workers aged 57+ if provided for by a sector‑level agreement.

    The CVE may include reduced working hours, mentoring duties, or responsibilities linked to knowledge transfer. It also provides a secure retirement pathway once the employee reaches statutory retirement age and qualifies for a full pension.

    Collective Bargaining obligations for larger employers

    Companies with 300 or more employees and with established trade unions are required to negotiate measures relating to the employment of senior workers.

    Negotiations must take place every three years, or every four years where a collective agreement is reached.

    Topics to be covered include recruitment and retention of senior employees, end‑of‑career measures (e.g., progressive retirement or part‑time work), and the organisation of knowledge transfer through mentoring or tutoring.

    Key measures in the 2026 Social Security Financing Act

    The 2026 Social Security Financing Act introduces several reforms that will directly affect employers, particularly larger organisations and those operating across the EU/EEA. While some measures offer modest relief, most changes will increase employer costs and compliance obligations.

    Higher employer contributions and new penalties

    A number of financial adjustments will take effect:

    • Increased contribution on severance and employer‑initiated retirements.
      The employer contribution applied to mutually agreed terminations and forced retirements rises from 30% to 40%. Plans to merge this levy with the social flat‑rate charge have been dropped.
    • New penalty linked to senior‑employment negotiations.
      Companies with 300+ employees, or EU/EEA‑sized groups employing at least 150 people in France, will face a penalty on old‑age and widowhood contributions if they fail to negotiate or implement an annual senior‑employment plan. The penalty level will be set by decree.
    • Adjustment to contribution reductions.
      To encourage industry‑level wage increases, the calculation of the general reduction in employer contributions will now be based on sectoral minimums that fall below the national minimum wage applicable only where those minima remain below the statutory level for the entire year.
    • Overtime relief extended to larger employers.
      The €0.50 flat‑rate deduction on employer contributions for overtime, previously limited to companies with fewer than 250 employees, now applies to all employers as of January 2026.

    Stricter rules on sick leave and indemnity payments

    The Act introduces tighter controls on medical leave. Initial sick leave will be capped at one month, with renewals limited to two months, unless a doctor provides specific justification.

    For workplace accidents and occupational diseases occurring from 1 January 2027, daily allowance payments will be subject to a maximum duration (to be set by decree). Currently, no such cap exists.

    Faster recognition of occupational diseases

    A new streamlined process will apply when a disease listed in the official tables meets all criteria except the time‑limit condition. Instead of referral to the CRRMP, cases may be reviewed by a panel of medical advisers who will issue a binding opinion for the National Health Insurance Fund.

    This accelerated mechanism isexpected to be in force by 1 January 2027, itmay increase employer exposure where gross negligence is established.

    Harsher penalties for undeclared work

    From 1 June 2026, surcharge rates on social contributions in cases of undeclared work will rise from 25% to 35%. The increased penalty will also apply to companies that fail to meet their due‑diligence obligations when engaging non‑compliant service providers.

    New paid birth leave

    A new birth‑related leave entitlement will be introduced:

    • available to each parent of a child born or adopted from 1 January 2026
    • one or two months of paid leave, which may be split into two periods
    • payable by Social Security at 70% of net salary for the first month and 60% for the second
    • must be taken after all maternity, paternity, child‑welcome or adoption leave has been used
    • effective 1 July 2026, with transitional rights for children born or adopted earlier in the year.

    What this means for employers

    Overall, the 2026 Act increases labour‑related costs and compliance duties. Key areas of impact include:

    • higher contributions on severance and retirement
    • new obligations around senior‑employment planning
    • increased penalties for undeclared work
    • potentially greater financial exposure in occupational‑disease cases
    • employers — especially larger organisations — should review their workforce policies, budgeting, and compliance frameworks ahead of these changes.
    Poland

    Steps taken to implement the EU Pay Transparency Directive

    Poland has published its draft legislation to implement the EU Gender Pay Transparency (read our earlier insight on the Transparency Directive). The law is expected to come into force on 7 June 2026. While amendments may still be introduced during the legislative process, the draft closely follows the provisions of the Directive, with several notable additions and clarifications for employers:

    • Pay progression information required for smaller employers: unlike the Directive employers with fewer than 50 employees will be required to provide pay progression information when requested by an employee.
    • Shorter deadline for pay information requests: employers will be required to provide employees with individual pay level information and average pay levels by gender within 30 days of the employee’s request (the Directive allows for a period up to two months). 
    • Employers will be required to implement remedial measures to counteract gender pay gaps within eight months of a joint pay assessment.

    Despite legislation not being scheduled until June 2026 progress has already been made on one areas of the Directive.

    On 24 December 2025 new regulations were enacted requiring employers to use gender‑neutral language in both job titles and job advertisements.

    Employers must also take proactive steps to ensure that their recruitment procedures are free from discrimination.

    Additionally, the legislation obliges employers to inform candidates about the salary level or salary range for the position and prohibits asking applicants about their previous pay.

    Portugal

    New social security reporting model

    Portugal is moving ahead with a major digital transformation of its Social Security system. Two new legislative instruments, Decree‑Law No. 127/2025 and Regulatory Decree No. 7/2025 introduce a modernised contributory reporting model aimed at simplifying and standardising employer reporting obligations. The new rules take effect 1 January 2026, with full mandatory compliance required from 1 January 2027.

    Key highlights

    • New digital reporting model applies from 1 January 2026, becoming fully mandatory from 2027.
    • Hiring, contract updates, and remuneration details must be submitted through designated online platforms.
    • Guaranteed Minimum Monthly Wage for 2026 set at EUR 920.00.
    • Statutory retirement age for 2027 established at 66 years and 11 months.

    New digital contributory reporting system

    The reforms require employers to interact with Social Security exclusively through digital channels. The core platform for employer reporting will be Segurança Social Direta.

    Reporting employment events

    New hires must be reported before the employment relationship begins. Required information includes the employee’s Social Security Identification Number, the type of contract, and details of permanent remuneration.

    Failing to report a new hire triggers a legal assumption that the employment relationship began earlier and that contributions remain payable.

    Contract terminations, suspensions, and amendments must be reported by the 10th day of the following month, with ongoing contribution obligations assumed until reported.

    Monthly remuneration declarations

    Remuneration records will consistently reference 30 days per employer, regardless of actual days worked. Employers must declare all amounts owed, including adjustments for periods of inactivity. Social Security will generate a calculated contribution amount based on declared remuneration and days worked. Employers will generally confirm this calculation unless amendments are required. Confirmation of each month's contribution is due by the 20th of the following month (except July). Payments must be made monthly, based on contribution data available between the 1st and 25th of the following month.

    Offence categories and corrections

    Failure to declare remuneration constitutes a very serious offence. Employers may correct or supplement their declarations within two months, with limited correction options available up to four months thereafter. Late corrections may escalate the offence classification from minor to serious.

    Implementation timeline

    1 January 2026: System becomes available and encouraged for use.

    1 January – 31 December 2026: Transitional period.

    1 January 2027: Digital reporting model becomes mandatory for all employers.

    What employers should do now

    Employers in Portugal should begin preparing for full compliance by:

    • Reviewing internal HR and payroll processes to align with the new digital reporting requirements.
    • Ensuring systems can support timely reporting of all employment‑related changes.
    • Training HR and payroll teams on new deadlines, platforms, and reporting workflows.
    Netherlands

    New compliance requirements for Highly Skilled Migrants from 1 January 2026

    From 1 January 2026, recognised sponsors of Highly Skilled Migrants (HSMs) and EU Blue Card holders will face stricter administrative duties and updated application fees. Organisations employing international talent should prepare now to ensure full compliance.

    Stricter administrative obligations for recognised sponsors

    Recognised sponsors must already demonstrate that HSMs and EU Blue Card holders meet the applicable salary thresholds. Until now, keeping payslips on file was sufficient.

    From 2026, this will no longer be enough. Sponsors must also prove that the salary has actually been paid to the employee.

    New mandatory documentation

    Sponsors will be required to keep:

    • bank statements from the company account showing salary transfers to the employee
    • batch payment overviews for monthly payroll runs.

    These records must clearly show that the salary was transferred to a bank account in the employee’s name.

    The IND’s goal is to strengthen oversight and prevent misuse of the highly skilled migration system. All documents must be retained for at least five years and must be available during audits or inspections.

    Why this matters for employers

    This is more than a procedural update, it significantly raises compliance expectations.

    Failure to maintain complete and accurate records may result in an IND audit, fines, suspension or loss of recognised sponsor status.

    Losing sponsor status would prevent an organisation from hiring new HSMs or EU Blue Card holders, creating major operational and recruitment challenges.

    To stay compliant, employers should ensure that payroll processes are transparent and traceable and that consistent documentation procedures are deployed to each case and full records maintained.

    Spain

    Proposed expansion of bereavement and family care leave

    The Spanish government and major trade unions have reached an agreement through the Social Dialogue Table to substantially expand paid leave entitlements related to bereavement and critical family care needs. Notably, the country’s main employers’ associations did not endorse the agreement, which may influence its legislative progress.

    Key proposed changes

    • Ten days of paid bereavement leave following the death of a family member, a significant increase from the current two–four days.
    • Fifteen days of paid leave for employees caring for a relative and receiving palliative care.
    • One day of paid leave to accompany an individual who has chosen to undergo euthanasia.

    Next steps

    The government will now draft a bill and submit it to Parliament for approval. While the agreement represents a meaningful step toward enhancing employee support during particularly difficult circumstances, similar proposals without employer association backing have previously faced challenges in the legislative process.

    UK

    Employment Law: what employers need to prepare for in 2026

    After a year dominated by parliamentary debate, the Employment Rights Act 2025 finally made it onto the statute books just before Christmas. While some measures will take effect this year, many of the most significant reforms are scheduled for 2027 and beyond. Alongside the new Act, several other legislative changes will reshape HR practice over the next 12–18 months.

    Below is an overview of the key developments:

    1. Pay and wage updates
      National Minimum Wage and National Living Wage

      From April 2026, wage rates will rise across all age groups:
      • National Living Wage (age 21+): up 4.1% from £12.21 to £12.71/hr
      • 18–20-year-olds: up 8.5% from £10.00 to £10.85/hr
      • apprentices: up 6% from £7.55 to £8.00/hr
      • 16–17-year-olds: up 6% from £7.55 to £8.00/hr.
        These increases exceed forecasted inflation, meaning real terms pay growth for workers.
      Statutory payments
      Also from April 2026, the weekly rate for statutory family related payments, including maternity, paternity, adoption, shared parental leave, neonatal care leave and parental bereavement leave, will rise to £194.32.
      Statutory Sick Pay (SSP) Reform

      Major changes are coming:
      • The Lower Earnings Limit (currently £125 per week) will be abolished, giving all employees access to SSP.
      • SSP will be payable from day one of sickness absence (removing the current three day waiting period).
      • The weekly SSP rate will increase to £123.25, or 80% of normal weekly earnings if lower.
      Employers operating ‘waiting days’ will need to update policies and contracts.
    2. Establishment of the Fair Work Agency (FWA)
      A new enforcement body, the Fair Work Agency is expected to launch in April 2026. It will consolidate several existing enforcement functions, including:
      • minimum wage and SSP enforcement
      • employment Tribunal penalty enforcement
      • Labour exploitation and modern slavery oversight.
      The FWA will also take responsibility for holiday pay enforcement and is expected to expand its remit over time. The exact start date for active enforcement remains to be confirmed.
    3. Family related rights
      Day one rights for paternity and parental leave
      From April 2026, employees will no longer need minimum service to qualify for:
      • paternity leave (currently 26 weeks’ service required)
      • unpaid parental leave (currently one year’s service required).
      Employees will also be able to take paternity leave after shared parental leave, offering greater flexibility for new parents.
    4. Harassment and employer liability
      From October 2026, employers will be legally liable if a third party, such as a customer or client harasses an employee during the course of their work. A defence will only succeed if the employer can demonstrate that all reasonable steps were taken to prevent harassment.
      This builds on the existing duty (in force since October 2024) to take reasonable steps to prevent sexual harassment, which will also be strengthened to require all reasonable steps from October 2026.
      Although the regulations explaining what counts as ‘all reasonable steps’ will not be published until 2027, employers should begin reviewing risk assessments and implementing preventative measures now.
    5. ‘Fire and rehire’ restrictions
      From October 2026, dismissing an employee to force changes to key contractual terms, such as pay, hours or holiday will be deemed automatically unfair. These are known as ‘restricted variations’. An exception will apply where the employer is in genuine financial difficulty. A consultation will clarify how this exemption will operate.
    6. Protective awards: significant increase
      Failure to comply with collective consultation obligations currently exposes employers to protective awards of up to 90 days’ pay. From April 2026, the maximum will double to 180 days’ pay.
      This makes compliance even more critical when:
      • meeting the new “threshold number of employees” test expected in 2027 under section 195A TULRCA.
      • proposing 20+ redundancies within 90 days, or
    7. Trade Union and industrial action reform
      Two months after the Employment Rights Act received Royal Assent (18 December 2025), most of the Trade Union Act 2016 will be repealed. However, two requirements will remain, albeit in amended form:
      • strike notice periods will reduce from 14 to 10 days
      • strike mandates will remain valid for 12 months (up from six).
      Further reforms expected in 2026 include:
      lower thresholds for statutory recognition (April 2026)
      • new obligations to inform employees of their right to join a union (October 2026)
      • new rights for unions to request workplace access (October 2026).
      These changes are likely to increase union presence and industrial action. Employers without recognised unions may wish to strengthen internal employee voice mechanisms to reduce the risk of disputes escalating.
    8. Longer time limits for employment tribunal claims
      From October 2026, the limitation period for most tribunal claims will extend from three months to six months. The only exception appears to be breach of contract claims on termination, although this may be clarified later.

    Most implementation dates (other than wage and statutory rate increases) follow the government’s published roadmap. While the government has reaffirmed its commitment to these timelines, recent experience suggests that delays are possible.

    A series of consultations is expected in the coming months. Employers are encouraged to participate directly or share views through representative bodies.

    Stronger dismissal protections for pregnant employees and new parents expected from 2027

    The Government is preparing to introduce significantly enhanced dismissal protections for pregnant women, new mothers and potentially other employees taking family‑related leave. These reforms are expected to take effect from 2027 and stem from new powers in the Employment Rights Act 2025.

    Current position

    UK law already prohibits discrimination linked to pregnancy or maternity. In redundancy situations, pregnant employees and new mothers benefit from priority protection: employers must offer them any suitable alternative vacancy.

    This protection begins once an employee notifies her employer of pregnancy and continues until 18 months after childbirth (or two weeks after the end of pregnancy where maternity leave is not available).

    Similar protections apply to employees on adoption leave and, in certain cases, shared parental or neonatal care leave. Dismissing someone for a reason connected to pregnancy or maternity leave is automatically unfair.

    So what’s changing?

    Using new powers under the ERA 2025, the Government intends to go further by making it unlawful to dismiss a woman during pregnancy, throughout maternity leave, and for at least six months after returning to work, except in tightly defined circumstances.

    A consultation launched in October 2025 sought views on:

    • when dismissal should still be allowed, and whether the list of potentially fair reasons should be narrower
    • when protection should begin and end, including whether it should apply from day one of employment
    • whether similar protections should extend to employees taking adoption, shared parental or neonatal care leave.

    The consultation closed on 15 January 2026, with detailed regulations expected later in the year.

    These reforms will significantly expand the safeguards available to employees during and after pregnancy, and employers should begin planning for the operational impact.

    Middle East and Africa


    Saudi Arabia

    New penalties introduced for workplace regulation breaches

    Saudi Arabia has introduced a wide range of substantial penalties for employers failing to comply with labour regulations, following a recent public consultation by the Ministry of Human Resources and Social Development. The updated fines address recruitment practices, maternity rights, childcare obligations, workplace investigations, and environmental compliance.

    Key penalties announced

    • Unlicensed recruitment and recruitment services
      • Employers engaging in unlicensed recruitment of nationals may face fines of up to SAR 200,000.
      • Operating unauthorised recruitment services attracts penalties ranging from SAR 200,000 to SAR 250,000, representing the highest fines in the new regime.
    • Improper employee deployment
      • Companies allowing workers to leave their roles and work for another party without authorisation will face fines between SAR 10,000 and SAR 20,000.
    • Maternity rights and childcare obligations
      • Maternity leave compliance: A penalty of SAR 1,000 will apply for each instance where employers fail to comply with maternity leave requirements.
    • Childcare provisions
      • Employers with 50 or more female employees and 10 or more children under six years old must provide childcare facilities, or they face a SAR 3,000 fine for non‑compliance.
    • Misconduct investigations and governance
      • The new rules impose fines of SAR 1,000 to SAR 3,000 for employers that fail to investigate workplace misconduct within five working days, or do not establish proper investigation committees.

    These measures reinforce the importance of internal governance and timely complaint handling.

    • Environmental compliance
      •  A new SAR 500 penalty will apply where employers breach internal or external environmental requirements. Although smaller in value, this fine reflects the growing emphasis on environmental responsibility within workplace regulation.

    What employers should do now

    Employers operating in Saudi Arabia should:

    • review their recruitment practices and licensing arrangements
    • ensure maternity leave policies and childcare arrangements meet statutory requirements
    • strengthen misconduct investigation procedures and timelines
    • confirm compliance with environmental standards
    • update internal policies and HR processes to reflect the new penalties.

    The updated framework significantly raises the stakes for non‑compliance and underscores the government’s focus on workplace standards, employee welfare, and regulatory transparency.

    Contact us


    Stuart Buglass
    Stuart Buglass
    Partner, HR Advisory, Global Business SolutionsCheltenham